Loans to shareholders or to related parties
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Current Account Deposits In Switzerland: Guide For French Residents
Current account contribution in Switzerland by a French resident: legal conditions, taxation, interest rates, and safeguards to avoid reclassification.
Services fiduciaires
Introduction
Under Swiss law, it is possible for a French resident to make a current account contribution (i.e., a loan) to a Swiss company, provided that he or she is a partner or shareholder holding at least 5% of the company’s capital (in an SARL or SAS, or even SA under certain conditions).
Main Conditions
- Minimum participation: at least 5% of the share capital, or being a manager/director holding this threshold.
- Applicable Swiss legal form: SARL, SA (or equivalents). The person must be duly registered as a partner/shareholder in accordance with Swiss statutes.
- Written agreement recommended: a current account contract between the partner and the company specifying remuneration (interest rate), duration, and repayment terms. This helps to properly frame the transaction for tax purposes.
Points of Caution
The remuneration of the current account must comply with the “safe-harbour” rates set annually by the Swiss Federal Tax Administration; otherwise, the loan may be reclassified as a disguised distribution, subject to a withholding tax of 35%.
The transaction must reflect a genuine loan intent (solvency of the partner, scheduled repayment, absence of unjustified private withdrawals, etc.) to avoid any tax reclassification.
Summary
Participation in capital
Minimum Condition≥ 5 %
Status in the company
Minimum ConditionPartner/shareholder or director with at least 5%
Loan agreement
Minimum ConditionContractual, in writing
Loan remuneration
Minimum ConditionInterest in line with published Swiss rates¹
For a French national domiciled in France, it is possible to become a partner in a Swiss company and make current account contributions, provided they hold at least 5% of the capital. This threshold allows the opening of a partner’s or shareholder’s current account in accordance with Swiss rules. It is then important to formalize this operation in writing, respecting applicable Swiss interest rates and good practices (clear contract, repayment terms, solvency checks, etc.) to avoid these contributions being reclassified as dividends.
¹ – see appendix
Appendix
1. Loans to shareholders or to related parties (in Swiss francs)
2. Loans from shareholders or to related parties (in Swiss francs)
Loans from shareholders or to related parties
To determine the CHF 1 million threshold, loans from shareholders and related parties must be aggregated.
These are ‘safe haven’ interest rates, with higher rates only justifiable when compared to third-party conditions.
¹ Up to and including CHF 10 million: ½% ; above CHF 10 million: ¼%
² When calculating the maximum tax-deductible interest, the possible existence of hidden equity must be taken into account. See FTA Circular no. 6a of 10 October 2024 concerning hidden equity for corporations and cooperatives (Art. 65 LIFD), also applicable for withholding tax and stamp duty.
Alice Meier
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