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SFTA circular letters regarding safe haven interest rates for 2023 – Material increases in safe haven interest rates

The Swiss Federal Tax Administration published the new circular letters regarding safe haven interest rates on advances and loans in Swiss francs and in foreign currencies for 2023.


In line with the current situation, interest rates in Swiss francs as well as in foreign currencies are experiencing material increases almost across the board.


For advances to participants in Swiss francs, a minimum interest rate of 1.5% (2022: 0.25%) is now required for advances/loans financed by equity. For advances/loans financed by debt, the surcharge on the cost price remains at 0.25% to 0.5% (above Fr. 10 million or up to and including Fr. 10 million), which must also be at least 1.5%.


In the case of advances/loans from participants, the maximum interest rate also increases accordingly. In the case of real estate loans, there is almost a doubling of the interest rates applicable from the previous year. In the case of operating loans, a further distinction must be made between trading and manufacturing companies as well as holding and asset management companies. The maximum interest rates range from 2% to 3.75% (2022: 0.75% to 3%) depending on the loan amount of less than or more than Fr. 10 million.


Regarding safe haven interest rates for foreign currencies, the interest rates for loans or advances in EUR (from 0.5% to 3%), USD (2% to 3.75%) and GBP (1.25% to 5.25%), among others, were massively increased. The list of increases in foreign currencies can be extended at will.


Due to the significant increase in the safe haven interest rates for 2023, it is even more worthwhile to once again review intercompany financing using the arm's length principle. For any further questions or advice, please contact Remo Merz, Swiss certified tax expert,




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Remo Merz, 9 February 2023