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On 27 and 28 January 2025, the Swiss Federal Tax Administration published the 2025 editions of the two circulars on safe harbour interest rates. The Administration uses the 5-year SWAP rates and the yield on long-term bonds in the various currencies as a basis, which rebounded at the end of 2024 despite central bank rate cuts. For this reason, compared to 2024, the safe-harbour interest rates are falling only for CHF denominated loans, while they remain the same for EUR (2.50 %) and USD loans (4.25 %) and are rising for GBP (4.50 %) and JPY loans (1.25 %).
The 2025 minimum interest rate for CHF loans to related parties is 1.00 % (down from 1.50 % in the two preceding years), to the extent refinanced by equity. The maximum rate for borrowing from related parties by operating entities corresponds to the weighted average of 3.50 % (previous year: 3.75 %) for the first CHF 1 million of related party borrowing and 1.75 % (prior year: 2.00 %) for any additional amounts of related party borrowing. As usual, any rates beyond the safe harbour should be accepted to the extent substantiated by third-party comparison.
The standard capitalization rate used by tax authorities for business valuations is calculated from the moving average of the market interest rates of the three previous years and thus lags behind recent developments. It has risen in CHF contrary to the latest market trend. The standard rate for valuations with a balance sheet date from 1 January 2024, as published in December 2024, is now 8.75 % (previous year: 7.75 %). The change leads to lower valuations of shares in unlisted companies.
Click here for the 2025 circular on safe harbour interest rates for CHF denominated loans.
Click here for the 2025 circular on safe harbour interest rates for loans in foreign currencies.