Switzerland: Tax Administration announces safe harbor inter-company interest rates for 2017

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The Swiss Federal Tax Administration (SFTA) published safe harbor interest rates on intra-group loans in Swiss Franc as well as in foreign currencies. On 13 February 2017, SFTA released a circular in relation to safe haven interest rates.

According to circular, loans granted to shareholders or related parties, the minimum interest rate for Swiss franc (CHF) is 0.25% in terms of equity finance. For debt financing, actual cost plus at least 0.5% interest rate is applicable on amount up to CHF 10 million and 0.25% on more than CHF 10 million.

The maximum interest rate for Swiss franc (CHF) loan made from related parties is 1% to 2.25% for real estate loans depending on loan type and level of debt financing.  In case of operational loans received from a commerce and industry, a 3% interest rate for amounts up to CHF 1 million and 1% for any surplus amount. And loans received from holding and investment management, a 2.5% interest rate for amounts up to CHF 1 million and 0.75% for any excess amount.

The tax administration also published another circular dated on 14 February 2017 regarding safe harbor rates for loans denominated in a foreign currency. The safe harbor rates for loans denominated in US dollars and Euros are 2.25% and 1% respectively.

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