Publication of tax-allowable interest rates on advances or loans with shareholders or between companies in the same group in 2025

As part of corporate financial management, loan relationships between shareholders and companies, or between companies in the same group, are commonplace and provide valuable cash flow flexibility.

However, because of the tax issues and the risks of requalification by tax authorities to avoid undesirable adjustments.

In this capacity, the Swiss Federal Tax Administration (FCA) published a circular letter on January 27 setting out the rates tax-allowable rates .

These rates are not mandatory, but serve as a benchmark to ensure that intra-group or shareholder-company transactions comply with arm’s length conditions.

In line with market trends, the interest rates recommended by the are subject to significant variations. For example, the minimum interest rate for a loan in Swiss francs from a company to its shareholder has risen from 0.25% in 2022 to 1.00% in 2025 peaking at 1.50% in 2023 and 2024.

We remind you that by respecting the recommended tax rates, subject to the existence of a problem of concealed equity capital, companies ensure that they avoid the risk of risk of requalification tax adjustments, both at shareholder and legal entity level.

In fact, advances or loans granted without interest, or with insufficient interest insufficient interest to shareholders or closely related third parties can be reclassified as cash benefits , with potential direct and withholding tax consequences.

The same applies to interest paid at an excessive rate. excessive rate on loans to shareholders or their relatives.

Finally, we would like to point out that, in principle, it is possible to deviate from the interest rates recommended by the by the FCA, provided that such deviations are justified by appropriate comparisons with rates applied in transactions with independent third parties, i.e. on the basis of the arm’s length principle. arm’s length . Ultimately, the tax authorities will have to agree to the rates applied.

The 2025 rates can be consulted directly on the AFC website.

This publication contains general information and is not a substitute for detailed research or expert advice. No liability can be accepted for its content. For specific questions, please contact the author.