Swiss Safe Harbor Interest Rates Decline in 2026

The Swiss Federal Tax Administration (SFTA) has published its safe harbor interest rates for intercompany loans and advances denominated in Swiss francs and foreign currencies.

The rates, which apply retroactively from January 1, 2026, show a general downward trend compared to the previous year.

For Swiss franc-denominated loans granted by a Swiss resident company to a shareholder or related party, the minimum interest rates are as follows:

Loans to related parties in CHF (receivable): Minimum interest rate 2026: Equity-financed - 0.75%, Debt-financed (CHF 10 million or less) - Third-party cost of debt + 0.50% (minimum 0.75%), Debt-financed (exceeding CHF 10 million) - Third-party cost of debt + 0.25% (minimum 0.75%).

The maximum interest rates payable by Swiss entities for loans from related parties in CHF are also calculated, adding a specific spread to the minimum CHF lending rate.