Interest rate on loans between related parties for year 2026

In the Official Gazette No 150/2025, the Ministry of Finance published the 2026 annual market interest rate on loans between related parties which amounts to 2.65%.

This interest rate is the lowest or rather the highest tax-deductible interest rate that can be charged on loans between domestic and foreign related parties:

• If interest on loans provided to foreign related party is not charged or is charged at the lower interest rate than prescribed, corporate profit tax base of the loan provider must be increased for the interest at the prescribed rate or the difference between the interest at the prescribed rate and the charged interest rate.
• For the excessive loan interest rate charged by foreign related party, corporate profit tax base of the loan recipient must be increased for the difference between the charged interest and the interest at the prescribed rate.

This interest rate also applies to loans between domestic related parties if one of the parties is in a tax favourable position, i.e. if one of the parties:

• pays corporate profit tax at the rate which is lower than the prescribed corporate profit tax rate or does not pay tax at all (i.e. uses tax relieves); or
• utilises tax losses carried forward from previous period in the respective tax period.