The base rates for loans denominated in CHF (see circular letter) have all decreased compared to last year. Notably, the interest rates for equity-financed loans to related parties decreased from 1.5% (in 2024) to 1% (in 2025). Further, real estate loans from related parties decreased for both housing and agriculture (from 3% in 2024 to 2% in 2025) as well as for industry and commerce (from 3.5% in 2024 to 2.5% in 2025). Operating loans up to CHF 1 million decreased from 3.75% in 2024 to 3.5% in 2025 for operating activities and from 3.25% in 2024 to 3% in 2025 for holding activities. Meanwhile, the interest rates for operating loans exceeding CHF 1 million decreased from 2% in 2024 to 1.75% in 2025 for operating activities and from 1.75% in 2024 to 1.5% in 2025 for holding activities.
Due to the current interest rate environment, the base rates for non-CHF denominated loans (see circular letter) have changed in some cases. In particular, the GBP safe harbour interest rate has been increased from 3.75% in 2024 to 4.5% in 2025. Compared to last year, the rates for GBP denominated loans thus allow for a slightly higher interest rate on intra-group loans. The base rates for EUR and USD denominated loans remain unchanged at 2.5% (EUR) and 4.25% (USD), respectively.
The possibility to add an interest spread to the maximum interest rate for non-CHF denominated loans payable of a Swiss entity is maintained. For loan amounts up to the equivalent of CHF 1 million, a spread of 2.5% (operating activities) or 2% (holding activities) can be added; for loan amounts above the equivalent of CHF 1 million, a spread of 0.75% (operating activities) or 0.5% (holding activities) can be added. For example, for large USD denominated loans payable the maximum interest rate would be approx. 5% (USD base rate of 4.25% plus a spread of 0.75%).
For non-CHF denominated debt financed loans receivable, the interest spread (taxable margin) is still 50 bps (i.e., interest spread between related party loans receivable and payable).
A deviation from these interest rates remains possible by means of a third-party comparison, i.e., if the interest rates are at arm’s length. However, if such a comparison cannot be sufficiently evidenced, recent case law from the Swiss Federal Supreme Court (ruling no. 9C_690/2022 dated 17 July 2024) indicates that cantonal tax authorities are no longer bound by the safe harbour interest rates, but may themselves determine an arm’s length interest rate as part of the Swiss corporate income tax assessment. It remains unclear whether the SFTA will adopt a similar approach for Swiss withholding tax purposes.
Note that the application of unilateral safe harbour rates may fall under hallmark E.1. of the DAC 6 mandatory disclosure rules of the EU. Swiss companies applying the Swiss safe harbour interest rates on transactions with group companies domiciled in an EU member state should therefore be aware that these transactions might be reportable under DAC 6.
You can check the 2025 Swiss safe harbour interest rates for Swiss Franc (CHF) denominated transactions and for non-CHF denominated transactions in the PDF version below.
