Royalties paid by a U.S. taxpayer to a Chilean company for a license to distribute the Chilean company's feature film across various streaming platforms may be subject to a 10% rate of withholding on the gross amount of royalties under the Chile-U.S. income tax treaty, which includes a definition of royalties that expressly covers payments for the use or right to use cinematographic films.
If Chile also taxes the royalties, Chile must grant a credit for the withheld taxes.
Read a December 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 U.S. income tax treaty to private investment funds
- Application of Article 107 of the corporate income tax law to redeemable investment funds
- Tax Treatment of the "Simple Agreement for Future Equity" (SAFE)
- Declaration and payment of value added tax (VAT) in the simplified taxation regime for nonresident taxpayers
- Issuance of extemporaneous purchase invoice
- Application of general anti-abuse rule (GAAR) to corporate reorganization
- Disproportionate distribution of dividends in relation to capital
- Tax criteria applicable to the ISIF
- Credit for corporate income tax paid with the balance of existing VAT credit at the end of commercial activities
- Issuance of tax documents for interest charges in credit operations
- Instructions on capital repatriation
- Credit established in the Austral Law in case of economic infeasibility of investment project