ARTICLE · 13 APRIL 2015

Swiss Safe Harbour Interest Rates On Intra Group Loans For 2015

MLL Meyerlustenberger Lachenal Froriep Ltd

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Interest rates on intra group loans are a recurring topic. The Swiss Federal Tax Administration (FTA) publishes safe harbour interest rates on an annual basis in advance.

SwitzerlandTax

Michael Fischer

Interest rates on intra group loans are a recurring topic. The Swiss Federal Tax Administration (FTA) publishes safe harbour interest rates on an annual basis in advance. Their application will usually prevent unwelcome surprises. But there is more to it.

Annual guidance published by the FTA In its annually published advance guidance on intra group interest rates the FTA differentiates whether the Swiss company acts as creditor or debtor, what currency the loan was granted in and whether (real estate) security was provided. Excessive or insufficient interest rates may trigger tax consequences in particular for corporate income and withholding tax purposes (WHT).

CHF loans granted by Swiss companies

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