Swiss “safe haven” interest rates for 2026 and their application

Basic principle: third-party settlement and safe-haven rule

Intra-group financing and loans from and to shareholders or related parties are a perennial issue in practice – whether within Switzerland or across borders. The question arises time and again: What interest rate is recognized for tax purposes – and at what point is it no longer considered to be in line with the market?

The Swiss tax authorities generally accept any interest rate agreed between related parties, provided it can withstand third-party comparison. In practice, the safe-haven interest rates published annually by the Swiss Federal Tax Administration (FTA ) (see Swiss safe-haven interest rates for 2025 and their application) provide important guidance. If these interest rates are adhered to, the interest is deemed to be at arm’s length for tax purposes – a considerable administrative advantage.

Implementation in practice

Capital is regularly granted between affiliated companies or between a company and a related party (e.g. shareholder or partner) in the form of loans or advances. The key tax question here is: What interest rate would an independent third party have agreed?

There are two ways to answer this question:

1. Application of the FTA’s safe haven interest rates
   These are regarded as administratively accepted benchmarks. If the published minimum or maximum interest rate is adhered to, market conformity is assumed (see FTA circular ).
2. Individual third-party comparison by means of a transfer pricing study or specific market transaction
   A different interest rate can be used here if it can be demonstrated that it is in line with the market – for example by means of:

• a transfer pricing study (benchmarking analysis with comparable external financing)
• specific refinancing plus an additional profit margin if applicable (e.g. back-to-back structure)
• a financing agreement with external lenders under similar conditions

This second option is necessary in many cases, particularly in the case of intra-group financing with foreign companies, as the safe-haven rates are only binding vis-à-vis the Swiss tax authorities. Foreign countries also have such safe-haven interest rates, e.g. the US tax authorities (Internal Revenue Service [IRS]; see IRS interest rates), so that in some cases it is even possible to find an interest rate that is accepted as a safe-haven rate by both tax authorities.

If the interest rate is not accepted by the Swiss tax authorities, the difference to the safe-haven interest rate or the market interest rate is treated as a hidden profit distribution or profit anticipation. This means that if the interest expense is too high, the debtor will not be allowed to deduct it (at least in part) or if the interest income is low, the creditor will receive a taxable profit offset. In addition, Swiss withholding tax of 35% is due on this difference and penalty taxes are also not excluded.

👉 Safe haven or third-party comparison? Use the decision flowchart and check your interest rate step by step.

Loans on the assets side vs. loans on the liabilities side

The FTA makes a clear distinction between two types of intra-group financing to determine the safe-haven interest rates:

• Loan Receivables:
  A Swiss company grants a loan to a shareholder or a related company.
  → Minimum interest rate: This must at least cover the lender’s own costs (e.g. the refinancing interest rate) plus a margin. In addition, the FTA sets a minimum interest rate each year, which may not be undercut.
• Loan Payables
  A Swiss company receives a loan from a shareholder or a related company.
  → Maximum interest rate: This may not exceed the normal market interest rate on borrowed capital in order to avoid a hidden profit distribution. The FTA sets a maximum interest rate each year, which may not be exceeded.

Type of loan: operating loan or real estate loan

In the case of liability loans (loans to a Swiss company), the safe haven rules also differentiate according to the use of the funds:

• Operating loans: serve to finance the operating business, e.g. current assets, investments or participations.
• Real estate loans: are used to finance land and real estate.

Real estate loans are considered particularly secure, which is why lower maximum interest rates apply here than for business loans.

A distinction is also made between the type of borrower for business loans:

• Trading and manufacturing company
• Holding or asset management companies

As the former tend to bear higher operating risks, the tax authorities there also accept higher interest rates.

Granting of the loan in Swiss francs or in a foreign currency

The minimum and maximum interest rates differ depending on the currency in which a loan is granted. If a Swiss company takes out a foreign currency loan from a related person or company, the maximum interest rate is determined on the basis of the minimum interest rate defined for the currency and the permissible margin on the minimum interest rate. The permissible margin is identical to the margin that applies to loans in Swiss francs. If a Swiss company takes out a loan in a foreign currency, it must also justify to the Swiss tax authorities why it has not entered into a commitment in lower-interest Swiss francs.

Safe haven interest rates in 2026 for Swiss francs

a) Loan receivable Minimum interest rate, CHF (from Swiss company to related party)

Example: A Swiss company refinances itself at 0.8 %. It can pass on an intra-group loan of up to CHF 10 million at 1.3 % (0.8 % + 0.5 %) or higher. If the Swiss company had no financing costs, it would still have to charge an interest rate of at least 1.0 %.

b) Loans payable Maximum interest rate for operating loans, CHF (to Swiss company of related party)

*All loans from participants and related parties are added together to calculate the limits.

c) Loan payable Maximum interest rate for real estate loans, CHF (to Swiss company of related party)

Lower rates traditionally apply to real estate loans. In 2026, the maximum interest rates for real estate loans granted to Swiss companies by related companies or persons (depending on the type of property and amount of the loan) range between 1.25% and 2.50%.

Safe haven interest rates 2026 for foreign currencies (example EUR)

a) Loan receivable, minimum interest rate, EUR (from Swiss company to related party, without foreign currency risk)

*If there is a foreign currency risk (e.g. if the Swiss company does not use the euro as its functional currency), the minimum margin is always at least 0.50 %.

b) Loans payable Maximum interest rate for operating loans, EUR (to Swiss company of related party) – Maximum interest rate for operating loans

*For the calculation of the aforementioned limits, the loans of all participants and related parties must be added together.

Borders and international aspects

The safe haven interest rates are only binding for Swiss tax purposes.
As soon as a group company abroad is affected, the foreign tax authorities assess the interest rate according to their own transfer pricing rules. When determining the market interest rate, most foreign tax authorities, like the Swiss tax authorities, are guided by the OECD Transfer Pricing Guidelines, but often require detailed evidence.

In addition, the application of Swiss safe haven interest rates for cross-border EU financing may trigger a reporting obligation under DAC 6 (Hallmark E.1). In this case, a prior check by the tax advisor in the EU country concerned is recommended.

Financing situation and equity ratio

Irrespective of the interest rate, the Swiss tax authorities check whether the borrower is sufficiently self-financed. If it is determined on the basis of the thin capitalization rules that part of the liability-side loan has the economic character of equity, the corresponding interest is not recognized as an expense for tax purposes, but is treated as a hidden profit distribution (dividend). In addition to the fact that this part of the interest expense is not deductible for tax purposes, Swiss withholding tax of 35% is payable on the dividend.

A healthy equity ratio is therefore a prerequisite for interest deductions to be granted in full. If there is a risk of a hidden profit distribution or if such a distribution has already taken place, it is essential to act quickly in order to prevent or at least reduce the withholding tax and any penalty tax consequences.

Current case law

The Federal Supreme Court (ruling 9C_690/2022 of July 17, 2024) has clarified that the tax authorities are only bound by the safe-haven rates published by the FTA if the company itself adheres to them.
If the taxpayer deviates from this, the authorities may determine the market interest rate independently – but must also provide evidence of the third-party comparison in this case.

Recommendations from the field

1. Contractual clause on interest rate adjustment:
   Loan agreements should stipulate that the interest rate can be adjusted annually to the published safe haven values.
2. Documentation of the third-party comparison:
   If the interest rate deviates from the safe-haven interest rate, it is highly recommended to document the third-party comparison in writing or even to obtain a benchmark analysis in order to prove market conformity.
3. Obtain a tax ruling:
   In the case of complex (e.g. cash pooling, internal house bank) or cross-border financing, a tax ruling with the cantonal tax administration and possibly the FTA is worthwhile – especially if large amounts or several currencies are involved.
4. Coordination with foreign tax advisors:
   In order to avoid DAC 6 risks or double taxation, intra-group interest rates should be coordinated across borders.

Conclusion

The Safe Haven Interest Rates 2026 provide Swiss companies with clear and practical guidance for intra-group financing. They reduce the risk of discussions with the Swiss tax authorities – but are not a substitute for analysis in individual cases.
Individual documentation of market conformity is particularly important for international group structures, cash pooling or back-to-back financing.

BrinerTax Insight:
I support companies in the structuring, auditing and documentation of intra-group financing – from the determination of interest rates to third-party comparisons and tax rulings.

Your path to predictable tax security

Plannable, secure, personal:
Choose the right package – strategy, compliance or head-of-tax – including portal, deadline control and ruling option.
👉 To the offers & packages

Or arrange a non-binding introductory meeting:
Free of charge, 30 minutes, in Basel by phone or video conference
👉 To the introductory meeting
I look forward to working with you to develop the optimal tax strategy.

FAQ – Frequently asked questions about financing between related parties

About the Author

Adrian Briner
Certified Swiss Tax Expert / Certified Public Accountant
Founder and Owner of Briner Tax Advisory AG

With over 15 years of experience in Swiss and international corporate tax law, Adrian Briner advises companies, entrepreneurs and CFOs on complex tax issues – from restructurings, financing and employee participation plans to international tax rulings.
His focus is on providing tax advice to SMEs, as well as life science and tech companies.

What you can expect: practical solutions, documented legal certainty, and privacy by design. Client data is processed exclusively in Switzerland, end-to-end encrypted.

BrinerTax processes all client data exclusively in Switzerland, end-to-end encrypted and in compliance with Swiss DPA and GDPR.
Basel | Olten 🌐
www.brinertax.ch