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Chile: Proof of U.S. residency under income tax treaty; other direct and indirect tax developments

A KPMG report concerning direct and indirect tax-related topics.

August 23, 2024

The tax authority (SII) ruled in Ruling No. 1450/2024 that if a taxpayer cannot obtain a certificate of U.S. residency because the U.S. tax authority issues it only for application of current income tax treaties, other documents issued or authorized by the competent tax authority of the United States may be submitted to Chile to prove tax residency for purposes of being eligible for the full corporate income tax credit with respect to dividends.

Read an August 2024 report (Spanish and English) prepared by the KPMG member firm in Chile

Other direct and indirect tax-related topics discussed in this report include:

  • Application of Chile-U.S. income tax treaty to Chilean mutual funds and investment funds (Ruling No. 1338/2024)
  • Requirements to be a beneficiary of Chile-U.S. income tax treaty (Ruling No. 1446/2024)
  • Additional tax on sales or imports of nectars, isotonic drinks, and hypotonic drinks (Circular Nos. 31/2024 and 33/2024)
  • Tax basis of shares paid through capitalization of accounts receivable and application of the general anti-avoidance rule (Ruling No. 1339/2024)
  • Value added tax (VAT) on concession for the exploitation and maintenance of advertising associated with kiosks (Ruling No. 1449/2024)
  • Imparts instructions on the temporary exemption from stamp tax on loans with mortgage guarantee (Circular No. 32/2024)
  • VAT and income tax effects of not complying with requirements to qualify as a professional company (Ruling No. 1333/2024)
  • Tax treatment of research and development expenses under tax incentive for private investment (Ruling No. 1489/2024)
  • Form to declare and pay substitute tax for final taxes (ISIF) (Resolution No. 76/2024)
  • Application of quarterly price readjustment under mining royalty law (Ruling No. 1538/2024)
  • Tax treatment of donations made to the National Reconstruction Fund (Circular No. 35/2024)

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