Safe haven interest rates for 2026

If loans from Swiss companies to their shareholders or other related parties (loan receivables) do not bear sufficient interest, this constitutes a pecuniary benefit to the extent of the underpayment of interest. Such pecuniary benefit may be subject to Swiss withholding tax as well as corporate income taxes.

If loans from shareholders or other related parties to Swiss companies (passive loans) bear excessively high interest, this constitutes a monetary benefit WHT to the extent of the excess interest and a hidden distribution of profits to be offset for profit tax purposes.

The Federal Tax Administration (FTA) publishes so-called safe haven interest rates annually. When these "official" interest rates are applied, the FTA assumes without further evidence that the interest paid is in line with market conditions. The correct application of these safe haven interest rates therefore protects against negative surprises and, above all, provides companies based in Switzerland with legal and planning certainty with regard to their financing activities. The FTA published the interest rates applicable for 2026 online in its annual circular on January 29 and 30, 2026.

Loans in Swiss francs from Swiss companies (loan receivables)

For equity-financed loans in Swiss francs granted by a Swiss company to its shareholders or other related parties, the FTA will require a lower minimum interest rate of 0.75% in 2026 (2025: 1%).

For debt-financed loans, the minimum interest rate required by the FTA for 2026 corresponds – as in previous years – to the Swiss company's debt financing costs plus a surcharge of 0.5% for loans up to CHF 10 million (or a surcharge of 0.25% for amounts exceeding CHF 10 million). These minimum interest rate requirements ensure a minimum net income from lending at the level of the Swiss company.

Loans in Swiss francs to Swiss companies (loan payables)

For loans received by a Swiss company from shareholders or other related parties, the SFTA allows maximum interest rates as follows:

Operating loans of up to CHF 1 million to a Swiss trading or manufacturing company in Swiss francs may bear interest at a maximum rate of 3.5% (as before) or, from CHF 1 million, at a maximum rate of 1.5% (previously 1.75%).

Loans to holding and asset management companies may bear interest at a maximum rate of 3% (as before) or, from CHF 1 million, at a maximum rate of 1.25% (previously 1.5%).

Loans in foreign currencies from Swiss companies (loan receivables)

If loans are granted in a foreign currency rather than Swiss francs, other safe haven interest rates apply. The FTA publishes the permissible interest rates for the most common foreign currencies in a separate circular.

Interest rates for loans in foreign currencies show varying trends compared to 2025. While the safe haven interest rate for EUR remains unchanged at 2.5% compared to the previous year, the interest rate for pound sterling (GBP) has fallen by 0.5 percentage points and the interest rate for USD by 0.25 percentage points.

Loans in foreign currency to Swiss companies (passive loans)

The interest rates specified in the table in the circular apply to loans granted by Swiss companies to shareholders or related third parties. In line with a safe haven solution, according to the FTA, for loans in foreign currency from shareholders or related parties to Swiss companies, the same spread (up to the equivalent of CHF 1 million 2.75% or 2.25%; from the equivalent of CHF 1 million 0.75% or 0.5%).

When applying the circulars, it should be noted that safe haven interest rates are calculated based on the respective interest period and not on the interest maturity date. For example, for an annual interest maturity date of June 30, 2026, an average rate of the safe haven interest rates for the years 2025 and 2026 applies.

Case study: Loan payable in USD

A parent company based in the USA holds 100% of the shares in a Swiss manufacturing company. The US parent company grants the Swiss company an open-ended loan of USD 2 million from January 1, 2026 (assumption: CHF-USD exchange rate = 1:1), with interest payable annually at the end of each year.

The permissible interest rate for USD loans in accordance with Circular 2026, taking into account a spread analogous to that for loans in Swiss francs, is 6.75% for loans up to the equivalent of CHF 1 million (i.e., 4% plus a spread of 2.75%). For loans with a value of CHF 1 million or more, the permissible interest rate is 4.75% (i.e., 4% plus a spread of 0.75%).

This means that the USD 2 million loan can be subject to interest at a maximum rate of 5.75% [6.75% plus 4.75% divided by two] in the 2026 interest period, in line with safe haven interest rates.

Conclusion

Following the significant increase in permissible safe haven interest rates in 2022 and 2023, these have tended to fall again in the last two years, in line with the general interest rate trend. This trend is particularly evident for 2026: all tax-recognized interest rates for advances or loans in both Swiss francs and foreign currencies have fallen or remained unchanged compared with the previous year.