We are pleased to inform you in today’s newsletter about the following topics:
- Arm’s length interest rates of cash pools
- ANOBAG – Occupational benefits insurance
As part of a tax audit in Swiss companies regarding income or withholding tax, almost always the interest on loans from and to group companies is audited. Also regularly reviewed is the interest rate of cash pools in terms of its qualification as “at arm’s length”. Experience has shown that – whether and to what extent the interest rates as per the annually published circular letter of the Swiss federal tax administration (CL SFTA) are applicable to cash pools – is not handled in a uniform manner.