Updated 23.05.2024

Shareholder’s borrowing agreement 

Loan from a company to its shareholder at the minimum tax-qualified interest rate.

Use this contract: 

  • If you are a shareholder or partner in a Swiss or foreign company.
  • You have borrowed funds from the company or have a current account with the company.
  • You wish to formalise the current account or determine the repayment terms.
  • You wish to apply the minimum interest rate, recalculated each year, as required by the tax authorities, without needing to amend the contract each year.




This contract is governed by Swiss law and complies with tax legisltation

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Protect yourself legally as a company with the following options: 

  • Indication of the minimum interest rate, the rate of which corresponds to the Federal Tax Administration’s circular. 
  • Automatic adjustment of the interest rate each year in line with changes in the practice of the tax authorities. 
  • Possibility of requesting regular interest payments instead of a one-off payment on the due date. 

Safeguard your interests as a shareholder by using the following clauses: 

  • Compliance with the arm’s length principle between related parties to avoid any tax risk. 
  • Possibility of early repayment, in whole or in part, with cessation of interest. 
  • No penalties or guarantees other than those provided for by law or required by the tax authorities. 
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