The Swiss Federal Tax Administration has published two circulars on the safe harbor interest rate limits for shareholder and related party financing for 2024. The rates depend on whether the financing is in Swiss francs or in a foreign currency.
- Loans to shareholders or related parties:
- financed through equity - at least 1.5%
- financed through debt - actual interest expense (cost) plus 0.50% for amounts up to CHF 10 million, plus 0.25% for amounts exceeding CHF …