On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs or a foreign currency.
Loans to shareholders or related parties:
- financed through equity – at least 1.5%;
- financed through debt – actual interest cost including 0.50% for amounts up to CHF 10 million, plus 0.25% for amounts exceeding CHF 10 million. but in any case, at least 1.5%.
Loans from shareholders or related parties:
- real estate loans – a maximum of 2.25% to 3.50%
- business loans received by:
- commercial and industrial companies – a maximum of 3.75% for amounts up to CHF 1 million and 2.0% for amounts exceeding CHF 1 million;
- holding and asset management companies – a maximum of 3.25% for amounts up to CHF 1 million and 1.75% for amounts exceeding CHF 1 million.
Financing in Foreign Currencies
Loans to or from shareholders or related parties:
- Financed through equity – 2.50% if in EUR, 4.25% if in USD, and between 0.50% and 10.25% for other currencies;
- Financed through debt – actual interest cost including 0.50%, with a minimum of 2.50% if in EUR, 3.75% if in USD, and between 0.50% and 10.25% for other currencies.
