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The base rates for loans denominated in CHF (see circular letter) have in some cases decreased compared to last year. While the interest rates for equity-financed loans to related parties (1.5%), real estate loans from related parties for both housing and agriculture (3%) as well as for industry and commerce (3.5%) and operating loans up to CHF 1 million (3.75% operating activities; 3.25% holding activities) remain unchanged compared to the previous year, the interest rates for operating loans exceeding CHF 1 million decreased from 2.25% (operating activities) in 2023 to 2% in 2024 and from 2% (holding activities) in 2023 to 1.75% in 2024.
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 EUR safe harbour interest rate has been reduced from 3.00% in 2023 to 2.5% in 2024 and the GBP safe harbour interest rate has been reduced from 5.25% in 2023 to 3.75% in 2024. The USD safe harbour interest rate has been increased from 3.75% in 2023 to 4.25% in 2024. Compared to last year, the rates for USD denominated loans thus allow for a slightly higher interest rate on intra-group loans, while the rates for EUR and GBP denominated loans require a slightly lower interest rate 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 above the equivalent of CHF 1 million, a spread of 0.50% (operating activities) or 0.25% (holding activities) can be added. For example, for large USD denominated loans payable the maximum interest rate would be approx. 4.75% (USD base rate of 4.25% plus a spread of 0.50%).
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 2024 Swiss safe harbour interest rates for Swiss Franc (CHF) denominated transactions and for non-CHF denominated transactions in the PDF-version below.
