The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss francs and foreign currencies for the year 2023. The SFTA uses these rates to assess the arm’s length nature of interest on intragroup loan receivables or payables. The safe harbor interest rates for 2023 apply retroactively as from 1 January 2023.
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