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The granting of interest free loans in foreign currency towards shareholders or affiliated parties or excessive interest payments on loans given by shareholders or affiliated parties in Swiss francs and foreign currency are considered as hidden distributions. The Swiss Federal Tax Administration has therefore published guidelines for the measurement of adequate interest rates. The most important interest rates applicable in 2012 are as follows:
EUR = 2.5%
USD = 2.0%
GBP = 2.5%
CAD = 2.25%