Tax-approved interest rates 2025 for advances and loans

On 27 and 28 January 2025, the Swiss Federal Tax Administration (SFTA) published two updated circulars relating to interest rates recognised for tax purposes for advance payments and loans in Swiss francs and in foreign currencies (so-called safe haven interest rates) for the tax year 2025. Compared to last year, the interest rates for the tax year 2025 have slightly changed.

The minimum interest rate for loans to shareholders or related parties (loan receivables) was reduced to 1% (insofar as financed from equity). Accordingly, the maximum interest rates for loans from shareholders or related parties to Swiss companies (loan payables) have also fallen; for operating loans in Swiss francs exceeding CHF 1 million a maximum interest rate of 1.75% (2024: 2%) applies in respect of loans to trading and manufacturing companies and a maximum interest rate of 1.50% (2024: 1.75%) for loans to holding and asset management companies. Companies based in Switzerland should review the applied interest rates on the relevant loans and adjust them if necessary.

The interest rates are considered safe haven rules, meaning that, when applied, the SFTA assumes that such interest rates are at arm's length without further justification. The charging of higher or lower interest rates remains possible, subject to the taxpayer justifying that the terms are in line with the arm's length principle.