News Taxes

SFTA circular letters regarding safe haven interest rates for 2025 – Minimum and maximum interest rates in CHF have decreased

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 2025.

The interest rates in Swiss francs are subject to continuous reductions of 0.25% to 1%, while there are some shifts (primarily upwards) in the interest rates in foreign currencies. However, there is only one change in the key currencies.

For advances/loans to participants in Swiss francs financed by equity, the minimum interest rate is reduced to 1% (2024: 1.5%). The surcharge for debt-financed funds on the cost price remains at 0.25% to 0.5% (over CHF 10 million or up to and including CHF 10 million), whereby the interest rate must now also be at least 1%.

The maximum interest rate is also reduced in the case of advances/loans from participants. For property and operating loans, there is a linear downward adjustment of 1% (property loans) and 0.25% (operating loans) across all variants.

The tax-recognized interest rates for foreign currencies experienced some significant increases but remained unchanged for the EUR (2.5%) and USD (4.25%). For GBP, however, there was an adjustment to the market situation with an increase to 4.5% (2024: 3.75%).

Also check for 2025 whether your intragroup financing complies with the arm's length principle. For individual advice or further information, please contact Remo Merz, certified tax expert, at remo.merz@fineac.ch.

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

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Remo Merz, February 2025