Switzerland publishes updated safe harbour interest rates for 2026

The SFTA has released the 2026 safe harbour interest rates for intercompany and shareholder loans in Swiss francs and foreign currencies, effective 1 January 2026.

We observed two main developments:

• The safe harbour interest rates for Swiss Francs decreased or remained stable compared to last year.
• For most of the foreign currencies, the safe harbour interest rates have decreased in comparison to the previous year. 

The following are the main observations for transactions denominated in Swiss francs:

• Minimum interest rates for loans financed through equity: Reduction from 1.00% in 2025 to 0.75% in 2026. 
• Minimum interest rates for loans financed through debt: Reduction from 1.00% in 2025 to 0.75% in 2026.
• No changes have been made to the interest rates for real estate loans in either housing/agriculture or industry/commerce categories. 
• Maximum interest rates for operating loans over CHF 1m: Slight reduction for both trading or production companies as well as holding or asset administration companies.

For transactions denominated in foreign currencies, these are the main observations:

• Notable changes in the safe harbour interest rates applicable in 2026 for foreign currency denominated transactions. Whilst most foreign currency transaction rates (in 13 currencies out of a total of 24 published currencies) have decreased, five foreign currency transaction rates have increased and six remained unchanged compared to the interest rates that were applicable for 2025 (more details below). 
• Safe harbour interest rates for transactions denominated in EUR remained unchanged (2.50% for EUR transactions).
• Safe harbour interest rates for transactions denominated in USD have decreased (4.00% for USD transactions in 2026 compared to 4.25% for USD transactions in 2025).

Swiss taxpayers have flexibility to apply different interest rates; however, they must validate that these rates comply with the arm's length principle. In practice, this means that the interest rates must be corroborated with a transfer pricing study.

Minimum rates to shareholders

For loans denominated in Swiss francs provided to shareholders and related parties, the minimum interest rates that a Swiss company must receive are contained below:

The minimum interest rates for loans denominated in Swiss francs provided by a Swiss company to a shareholder or related party in 2026 have decreased compared to the rates in 2025 (0.75% vs 1.00%).

Maximum rates from shareholders

For loans denominated in Swiss francs received from shareholders and affiliated parties, the maximum interest rates that Swiss entities are permitted to pay are as follows: 

In 2026, the maximum interest rates for loans denominated in Swiss francs from related parties to a Swiss company have decreased compared to the rates in 2025. Please refer to our insights for the rates that were applicable in 2025

The SFTA has also published the safe harbour interest rates for loans denominated in 24 foreign currencies for 2026. These are illustrated in the table below, together with the safe harbour interest rates that were applicable in 2025.

As a general observation, whilst most foreign currency transaction rates (in 13 currencies out of a total of 24 published currencies) have decreased, five foreign currency transaction rates have increased and six remained unchanged compared to the interest rates that were applicable for 2025. 

For loan receivables of a Swiss company, these are the minimum interest rates that must be charged to a related party (note: if the CHF safe harbour rate is higher, then this higher rate must be charged). If a loan is debt financed, then a minimum spread of 0.50% must be applied, or at a minimum, the below presented interest rates.

These interest rates are also the maximum interest rates that a Swiss entity may pay to a related party for loans payable in a foreign currency. However, for operating loans the same spread, as for Swiss franc transactions, could be applied. For amounts up to the equivalent of CHF 1 million, the spread is 2.75% or 2.25%, and for amounts from CHF 1 million and above, the spread is 0.75% or 0.50%.

• It is important to note that whilst the interest rates listed above are safe harbours from a Swiss perspective, a transfer pricing study will need to be performed to demonstrate that the selected interest rates are at arm’s length for a transaction between a Swiss company and a foreign counterparty.
• Taxpayers should also note that transactions between a Swiss company and an EU based counterparty that utilise the safe harbour rates are required to disclose the transaction in the counterparty location as part of the DAC 6 regime.
• Tax administrations in Switzerland are continuing to pay closer attention to transfer pricing matters. Considering this focus on transfer pricing is observed both in Switzerland and worldwide, it is imperative for businesses to maintain and apply policies that are compliant with transfer pricing rules both here in Switzerland and in other countries.