The Swiss Federal Tax Administration has published circulars setting the 2026 safe-harbour interest rates for loans between shareholders and related parties, covering both Swiss Franc and foreign currency transactions.
The Swiss Federal Tax Administration ( FTA) has released circulars outlining the safe-harbour interest rates for loans between shareholders and related parties.
The circular covering loans in Swiss Francs (CHF) was issued on 29 January 2026, while the circular for loans in foreign currencies was published on 30 January 2026.
2026 Swiss safe harbour interest rates
Swiss Franc (CHF) denominated transactions
Loans to Related Parties (Minimum Values)
| Type | Condition | Rate |
| Loans financed through equity | — | 0.75% |
| Loans financed through debt | up to CHF 10 million | debt related costs + 0.5% (at least 0.75%) |
| exceeding CHF 10 million | debt related costs + 0.25% (at least 0.75%) |
Loans from related parties (maximum values)
Real estate loans
| Loan Amount | Housing and Agriculture | Industry and Commerce |
| Up to first mortgage amount (i.e., 2/3 of market value) | 1.25% | 1.75% |
| For the remainder, with maximum: • up to 70% for building land, villas, condos, holiday homes, factories • up to 80% for other properties | 2% | 2.5% |
Operating loans (CHF)
| Activity Type | Amount | Rate |
| Operating activities | up to CHF 1 million | 3.5% |
| exceeding CHF 1 million | 1.5% | |
| Holding activities | up to CHF 1 million | 3% |
| exceeding CHF 1 million | 1.25% |
Non-CHF denominated transactions
Non-CHF basis rates
| Country | Currency | 2025 | 2026 |
| European Union | EUR | 2.5% | 2.5% |
| USA | USD | 4.25% | 4% |
| Great Britain | GBP | 4.5% | 4% |
Loans to related parties (minimum values)
| Type | Rate |
| Loans financed through equity | non-CHF basis rates |
| Loans financed through debt | debt related costs + 0.5% (at least non-CHF rates above) |
Loans from related parties (maximum values) – operating loans
| Activity Type | Amount | Rate |
| Operating activities | up to CHF 1 million | non-CHF basis rates + 2.75% |
| exceeding CHF 1 million | non-CHF basis rates + 0.75% | |
| Holding activities | up to CHF 1 million | non-CHF basis rates + 2.25% |
| exceeding CHF 1 million | non-CHF basis rates + 0.5% |
