The Swiss Federal Tax Administration (SFTA) has published two Circulars with safe-harbor interest rates 2022 for advances and intercompany loans in Swiss francs as well as in foreign currencies.
Circular 195 of 27 January 2022
The minimum interest rates for loans in CHF granted to shareholders or related parties are 0.25% on loans financed through equity and on loans financed through debt, the interest incurred plus 0.5% on amounts up to CHF 10 million, or plus 0.25% on amounts exceeding CHF 10 million; in all cases, however, at least 0.25%.
Conversely, the maximum interest rates payable for loans in CHF granted by shareholders or related parties are on real estate loans 1.0% to 2.25% and on operational loans received by a Swiss trading or production company 3.0% for loans up to CHF 1 million and 1.0% on the excess; by a Swiss holding or administration company: 2.5% for loans up to CHF 1 million and 0.75% on the excess.
Circular 196 of 28 January 2022
For loans in foreign currencies applied to shareholders or related parties, the minimum interest rates are EUR: 0.50%, USD: 2.00% on loans financed through equity; in all cases, however, at least the safe haven interest rate for loans denominated in CHF, i.e. 0.25%; and the interest incurred (prime costs) plus 0.50% on loans financed through debt; in all cases, however, at least 0.50% for loans denominated in EUR, or 2.00% for loans in USD.
