The Federal Tax Administration publishes the tax deductible interest rates on loans in Swiss francs as well as in foreign currencies for the year 2016th For CHF, EUR and USD loans remain unchanged compared to the previous year.

Advances or loans in Swiss francs

In calculating a reasonable return of advances or loans in Swiss francs to participants or related third party or by parties or their related third parties, the Federal Tax Administration (FTA), the Department of Federal income tax, withholding tax, stamp duties, in accordance with Circular of 23 February 2016 since 1 January 2016 the following rates from:

For Advances to party or related parties (in CHF):  at least

  • financed by equity and if no debt must bear interest: ¼%
  • from debt financed: cost + ¼ - ½% (up to CHF 10 million ½% to CHF 10 million ¼%); least ¼%

For advances from parties or related parties (in CHF):  at most

  • Operating loans to CHF 1 million .: in trading and production companies: 3% ** / for holding and asset management companies: 2 ½% ** 
  • Operating loans from CHF 1 million .: in trading and production companies: 1% ** / for holding and asset management companies: ¾% **

** In calculating the tax maximum interest also MANO existing hidden equity is observed. Reference is made to the circular no. 6 of the direct federal tax of 6 June 1997 concerning hidden equity (Art. 65 and 75 DBG) thereto, which is decisive for the interests of the withholding tax and stamp duties.

For the calculation of the limits the credits of all stakeholders and related parties are to be counted together. These rates are considered "safe haven".

Proof of higher interest rates compared to third parties are reserved.

Advances or loans in foreign currencies

In calculating a reasonable return of advances or loans in foreign currencies to participants or related third party or by parties or their related third parties, the Federal Tax Administration (FTA), the Department of Federal income tax, withholding tax, stamp duties according to the circular of 24 February 2016 since 1 January 2016 for the given in a table to the interest rate (approximate). These are based partly on the 5-year swap rates and the other hand on the return of long-term investments such as corporate bonds. According to Circular apply to advances or loans in EUR and USD, the following rates:

  • EUR: 1%
  • USD: 2.25% 

The interest rates according to the table are as follows applicable:

For advances or loans to participants or related parties

If the rate of foreign exchange under the interest rate according to the circular of the FTA concerning tax-deductible interest rates in 2016 for advances or loans in Swiss francs of 23 February 2016, so at least the equivalent rate for Swiss franc is considered.

These rates are valid for advances or loans to participants or related third parties, provided that they are financed by equity.

If the company or cooperative entered into interest bearing obligations, advances or loans to participants or related third parties within the scope of interest-bearing liabilities to the capital rates plus a premium of ½%, but at least at the rates specified in this Circular are subject to interest.

For advances or loans from parties or related parties

In terms of a "safe haven" solution interest rates apply to income obligations in foreign currencies. If the rate of foreign exchange under the interest rate according to the circular of the FTA concerning tax-deductible interest rates in 2016 for advances or loans in Swiss francs of 23 February 2016 at an interest rate to the interest rate for Swiss franc is permitted by tax law.

However, it is possible to make higher interest rates due to the third comparison contends. In this case justified for business purposes must be proved in addition, which is why no commitment was made in deep-interest Swiss francs.

When calculating the tax maximum interest also MANO existing hidden equity is observed. Reference is made to the circular no. 6 of the direct federal tax of 6 June 1997 concerning hidden equity (Art. 65 and 75 DBG) thereto, which is decisive for the interests of the withholding tax and stamp duties.

For the evaluation of companies

To define the decisive for the evaluation of companies capitalization rate of interest, is subject to the following interest rates, a surcharge of 40 - making 50%. The supplement is but in any case at least 5%. Since the interest rate on reviews from 2004 for the Japanese yen (JPY) is lower than the interest rate for Swiss francs, respectively, was the corresponding rates in the table are specified separately.