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SFTA circular letters regarding safe haven interest rates for 2024 – Largely unchanged from 2023

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 2024.

The interest rates in Swiss francs are only subject to marginal adjustments, while there are some significant upward and downward shifts in the interest rates for foreign currencies.

For advances/loans to participants in Swiss francs financed by equity, the minimum interest rate remains at 1.5% (2023: 1.5%). Similarly, for debt-financed funds, the surcharge on the cost price remains at 0.25% to 0.5% (over CHF 10 million or up to and including CHF 10 million), although this must also be at least 1.5%.

In the case of advances/loans from participants, the maximum interest rate remains the same as in the previous year. Only for operating loans of CHF 1 million or more will the maximum interest rate be reduced to 2% (2023: 2.25%) for trading and manufacturing companies and 1.75% (2023: 2%) for holding and asset management companies by 0.25% in each case.

Regarding safe haven interest rates for foreign currencies, the interest rates for loans or advances in EUR (from 3% to 2.5%), USD (3.75% to 4.25%) and GBP (5.25% to 3.75), among others, have been adjusted to the current market situation.

Also check for 2024 whether your intragroup financing complies with the arm's length principle. For any further questions or advice, please contact Remo Merz, Swiss certified tax expert, remo.merz@fineac.ch.

Source: https://www.estv.admin.ch/estv/de/home/verrechnungssteuer/vst-zinssaetze.html

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Remo Merz, 19.02.2024