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The Swiss Federal Tax Administration recently published two circulars outlining the safe harbour interest rates applicable to shareholder and intercompany loans, denominated in Swiss Francs and foreign currencies, applicable for 2021.

Swiss taxpayers can deviate from these interest rates so long as they are able to demonstrate that the interest rates that they apply are in line with the arm’s length principle – in practice, this means that the interest rates must be supported by a transfer pricing study.