Swiss Supreme Court Holds Taxpayers Not Following Safe Harbor Interest Rate Rules Cannot Expect Tax Authority to Follow

The Swiss Federal Supreme Court issued a judgment on 17 July 2024 concerning the treatment of interest exceeding the arm's length and safe harbor rates in a case involving a foreign company (B AG) and its Swiss subsidiary (A AG). In 2013, B AG granted an unsecured loan to its subsidiary A AG with an interest rate of 2.5%, as well as a current account credit balance with an interest rate of 3.0…
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