Safe haven interest rates for advances
and loans in 2026

On 29 and 30 January 2026, the Federal Tax Administration (FTA) published two circulars valid for the 2026 tax year on tax-recognised interest rates for advances and loans in Swiss francs and foreign currencies (known as “safe haven” interest rates). Compared to the previous year, the interest rates for the 2026 tax year have changed slightly.

The minimum interest rate for advances and loans to shareholders or related parties (active loans) in CHF has been reduced to 0.75% (previous year 2025: 1%), provided they are financed from equity capital. Accordingly, the maximum interest rates for advances and loans to Swiss companies (passive loans) have also fallen: From 2026, a maximum interest rate of 1.5% (2025: 1.75%) will apply to operating loans in Swiss francs of CHF 1 million or more for trading and manufacturing companies, and 1.25% (2025: 1.5%) for holding and asset management companies. Companies based in Switzerland should review the interest rates applied to the relevant loans and adjust them if necessary.

There have also been some changes to the interest rates for loans and advances in foreign currencies. For loans in USD, for example, a minimum interest rate of 4.00% (2025: 4.25%) now applies.

The interest rates are safe haven rules. This means that the FTA assumes that the interest rates are in line with arm's length principles when applying them. Higher or lower interest rates are subject to proof of arm's length principles.