Base rates for CHF denominated loans (see circular letter) have increased in some cases compared to last year. Notably, loans to related parties financed through equity increased from 0.25% (in 2022) to 1.5% (in 2023). Further, real estate loans from related parties increased for both housing and agriculture as well as industry and commerce. Operating loans from related parties also saw an increase, with operating loans up to CHF 1 million increasing to 3.75% (operating activities) and 3.25% (holding activities) in 2023. Operating loans exceeding CHF 1 million increased to 2.25% (operating activities) and 2% (holding activities) in 2023.
Due to the current interest rate environment, base rates for non-CHF denominated loans (see circular letter) have also changed in most cases. Importantly, the EUR safe harbour interest rate has been increased from 0.5% (in 2022) to 3% (in 2023) and the USD safe harbour interest rate has been increased from 2% (in 2022) to 3.75% (in 2023). Further, the GBP safe harbour interest rate has been increased from 1.25% (in 2022) to 5.25% (in 2023). Compared to the previous year, the rates for EUR, USD and GBP denominated loans allow for higher interest rates on intra-group loans.
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 2.25% (operating activities) or 1.75% (holding activities) can be added, for loan amounts exceeding the equivalent of CHF 1 million a spread of 0.75% (operating activity) or 0.50% (holding activity) can be added. For instance, for large USD denominated loans payable the maximum interest rate would be approx. 4.5% (USD base rate of 3.75% plus 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).
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 2023 Swiss safe harbour interest rates for Swiss Franc (CHF) denominated transactions and for non-CHF denominated transactions in the PDF-version.