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Thomas Nabholz
Diana Daka
On 29 and 30 January 2026, the Swiss Federal Tax Administration published its annual circulars on the safe harbour interest rates for loans in Swiss francs and foreign currencies. The new circulars reflect the reduction in key interest rates in the major currency areas, with the exception of Japan, over the last 12 months.
For 2026, the safe harbour interest rates for CHF loans are slightly reduced compared to the previous year. The minimum interest rate for loans to related parties is now 0.75 % (previous year: 1.00 %) if the loan is financed from equity capital. If financed from debt capital, the interest rate plus a margin of ¼ % to ½ % applies, but at least 0.75 %.
For CHF loans from related parties, unchanged maximum interest rates of 3.50% for operating companies and 3.00% for holding companies apply up to CHF 1 million, and 1.50% and 1.25%, respectively, above CHF 1 million (each ¼ % less than in the previous year).
The safe harbour interest rates for loans in foreign currencies are based on 5-year swap rates and the yield on long-term bonds. Compared to 2025, the rates for USD and GBP are down (both now 4.00 %), while EUR remains unchanged at 2.50 % and JPY rises significantly to 2.00 %.
As always, interest rates beyond these safe harbour limits are also permissible, provided that adequate documentation is available demonstrating that the rates applied satisfy the arm’s length principle.
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 2025 is now 10.00 % (previous year: 8.75 %). The change leads to lower valuations of shares in unlisted companies.
Click here for the 2026 circular on safe harbour interest rates for CHF denominated loans (in German): https://www.estv.admin.ch/dam/de/sd-web/xY4pH-Qc2lrL/2-218-DV-2026-d.pdf
Click here for the 2026 circular on safe harbour interest rates for loans in foreign currencies (in German): https://www.estv.admin.ch/dam/de/sd-web/04KIslBDT-PZ/2-219-DV-2026-d.pdf
