Under a Circular of 30 January 2014 the safe harbor interest rate on loans received by shareholders or related parties denominated in CHF are 1.5% on loans financed through equity, or for loans financed through debt the safe harbor rate is the interest incurred on that debt plus 0.5% on amounts up to CHF 10 million; or plus 0.25% on amounts above CHF 10 million; provided that the interest rate is at least 1.5%. For loans made by shareholders or related parties the safe harbor interest rates are 1.5% to 2.75% on real estate loans (the amount depending on the type and level of debt finance); 3.75% on operational loans received by a Swiss trading or production company; or 3.25% on loans received by a Swiss holding or administration company. Other safe harbors apply for loans denominated in foreign currencies. On loans given to related parties or shareholders and financed from equity the safe harbor rates are 2.0% for EUR and 2.25% for USD denominated loans, but in all cases the rate must be at least 1.5%. For loans given to shareholders and related parties financed through debt the rate is the interest incurred plus 0.5%, but must be at least 2.0% for EUR loans and 2.25% for USD loans. The same safe harbor rates apply to foreign currency denominated loans received from shareholders or related parties, but higher interest rates may apply to these if they are justified by a business purpose.
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