In practice, loans from shareholders to “their” GmbH are regularly used as a financing instrument. Reported interest rates on advances or loans denominated in foreign currency. All construction savings rates are sorted by the lowest lending rate. You want to benefit from the currently favorable interest rate level? You can use the forward loan: eliminate the risk of rising interest rates; plan today with fixed monthly installments for the future; simply change – without effort for you.
On loans from related parties
in the publication on Fiscal Recognition Interest Rates 2015 of 12. 2. 2015, for advances For the first time, between operating payday loans of up to 1 million francs and higher amounts from participations in SFr. differentiated. What is the newsletter about “Tax Credits 2015 for Advances or Loans in CHF”? Non-interest-earning or insufficiently yielding advances or payday loans to participants or related parties constitute a contribution in kind.
The same applies to translated interests that are due to obligations towards the property of or in the vicinity of third parties. Each year, the Federal Finance Administration publishes a circular minimum interest rates (for loans to participants) and maximum interest rates (for loans from participants ). The published interest rate is called a “safe haven”. They can easily be claimed for taxation reasons, with changes under can be proven for.
This is now mentioned in the newsletter. For the current year (RS Z15), the Federal Finance Administration (FTA) has published the newsletter with the tax-privileged address interest rates for advances or loans to or from the Swiss franc participation. The RZ 15 bring content-specific innovations: Environment adapted.
In addition, a staggered upper limit has been introduced for working capital loans from participants and related third parties². So it’s in number 2. 2. 2. RZ Z15: “In addition to the interest rate franc, the bonds issued are published in a separate, annual journal in a variety of foreign currencies.
Another rate for Since 1999, there are working capital loans from commercial and industrial companies as opposed to holding companies and asset managers. 2. 2. 2 Working capital loans: This new regulation raises various questions: There are a number of questions: 1. Question: Interest on loans> 1 million francs The first is how far the 1 million franc limit is to be understood, ie whether in a commercial operation to a group company granted operating loans to over 4 million francs the entire 4 million francs the maximum rate of the lower rate of 1% of the interest rate is above (option I) or if the 1 million francs.
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A maximum of 3% and the remaining 3 million Swiss francs with a maximum interest rate of 1% will be paid on option II. Example: Loans from a trading company to an investment company may cost 4 million francs with option 2, the total interest rate being 1.5% of the total amount 4 million francs Option II is therefore from a business point of view to preferential.
According to our interpretation and according to the Free Trade Area, Option 2 is adopted in the application. Holding (HoldCo 1) grants the A subsidiary a loan and a subsidiary of the B a loan of CHF 1 million (Loan A) and a loan of CHF 3 million (Loan B). Holding 1 and Holding 2, which each hold 50% of Group company B, each have a loan of CHF 1 million (K1 loan and K2 loan).
In this example, for example, the subsidiaries do not know the loans C2 and only have to cumulate at the borrower level. This interpretation was confirmed verbally by the FTA on Nov. 26, 2015. In this example, the related loan amount for the subsidiary is 1 million francs, for the subsidiary, 3 million francs for the subsidiary.
Subsidiary A1 may make the entire loan amount payable at the higher interest rate, for subsidiary 3b reference is made to the example above with request 1. For the subsidiary K, the fundamental consideration arises as to how the interest rate service can or must be divided between the two loans K1 and K2. It is irrelevant, from the perspective of the Free Trade Agreement, whether loans from different investors have the same high yield as long as the specified maximum rates are retained without notice.
Subsidiary A is therefore tax-free regardless of whether it pays loans K1 and K2 at 2% (“average interest rate”) or whether it has (selects) another distribution. The content is not liable. For more information or more information, please contact your relationship manager or one of our 33 branch offices.