However, given recent international developments related to the G20/Organisation for Economic Co-operation and Development initiative to combat profit reduction and profit shifting (BEPS), this option could become increasingly popular, as more and more countries strive to put in place more reliable and faster procedures. Ultimately, popularity may depend on the jurisdictions involved. As a general rule, the Swiss tax authorities do not carry out transfer pricing investigations. However, on the basis of the ordinary tax procedure, the tax authorities verify the taxable person`s declaration and carry out the necessary investigations (Article 130(1) BSTÜ). If it is found that the company has paid constructive dividends, these dividends are subject to the withholding tax of 35% (in accordance with Article 4(1)(b) of the Withholding Tax Act of 13 October 1965); if the withholding tax is not borne by the beneficiary, the withholding tax is deducted at the gross rate of 54%. However, the beneficiaries of constructive dividends may demand a full or partial refund on the basis of Swiss national law (Article 24(1) of the Transfer Tax Act of 13 October 1965) or an applicable double taxation convention. Under certain conditions, a notification procedure may also be available for notification instead of payment of withholding tax.