Swiss GmbH + UAE IBC

[Runway]

Hello,
I have a Swiss GmbH with customers in Switzerland and EU and I am setting up a UAE IBC to use for transfer pricing. Most of the company activities are in Asia and I am in a country with territorial-tax.

Is it a good idea or will I have troubles with the swiss tax authority?

 

[negon]

You will have the same trouble with the tax authority as if you setup your business anywhere else offshore! UAE is reporting your accounts and everything else you are doing there exact same way as Belize, Seychelles, UK and all other CRS compliant countries!

 

[Runway]

I have no issues with CRS reporting, as stated I am resident in a 3rd country with territorial-tax system.
My doubts are on the transfer pricing part between the swiss entity and UAE, will the swiss authorities still tax the GmbH for the value invoiced and transferred to the UAE entity?