Swiss Federal Supreme Court rules on non-deductibility of interest in debt push-down structures
Swiss Federal Supreme Court rules on non-deductibility of interest in debt…
<p>In decision 9C_606/2025 of 24 February 2026, the Swiss Federal Supreme Court held that interest expenses on acquisition debt transferred to a target company through a downstream merger are not deductible where they lack a direct nexus to the target’s own business activity. The Court grounded its reasoning in the definition of commercially justified expenses and the principle of periodicity. It thereby relied on an explicit legal basis without invoking the tax avoidance doctrine.</p>