On 29 and 30 January 2026, the Federal Tax Administration (FTA)
published two circulars valid for the 2026 tax year on
tax-recognised interest rates for advances and loans in Swiss
francs and foreign currencies (known as "safe haven"
interest rates). Compared to the previous year, the interest rates
for the 2026 tax year have changed slightly.
The minimum interest rate for advances and loans to shareholders or
related parties (active loans) in CHF has been reduced to 0.75%
(previous year 2025: 1%), provided they are financed from equity
capital. Accordingly, the maximum interest rates for advances and
loans to Swiss companies (passive loans) have also fallen: From
2026, a maximum interest rate of 1.5% (2025: 1.75%) will apply to
operating loans in Swiss francs of CHF 1 million or more for
trading and manufacturing companies, and 1.25% (2025: 1.5%) for
holding and asset management companies. Companies based in
Switzerland should review the interest rates applied to the
relevant loans and adjust them if necessary.
There have also been some changes to the interest rates for loans
and advances in foreign currencies. For loans in USD, for example,
a minimum interest rate of 4.00% (2025: 4.25%) now applies.
The interest rates are safe haven rules. This means that the FTA
assumes that the interest rates are in line with arm's length
principles when applying them. Higher or lower interest rates are
subject to proof of arm's length principles.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
