Ruling No. 2396/2025 provides that the Chile-United States income tax treaty is applicable to both the funds managed by the unemployment fund management company (AFC), as well as to the AFC itself.
- Thus, income from financial assets invested in the United States received by a Chilean resident who meets the requirements of Article 24 on the limitation of benefits (LOB) will qualify for the benefits of the treaty.
- In addition, income generated by the AFC for its own account generally will qualify for the benefits of the treaty because the AFC is a closed joint-stock company subject to taxation in Chile on its worldwide income and thus will be considered a resident person of Chile under the terms of the treaty. It is also expected that the AFC will satisfy the LOB requirements under the treaty.
Read a January 2025 report (Spanish and English) prepared by the KPMG member firm in Chile
Other direct and indirect tax-related topics discussed in this report include:
- Anti-avoidance rules in asset contributions
- Sale of foreign shares subject to the voluntary and extraordinary declaration system of assets or income
- Criteria to define a case as relevant or of institutional interest
- Reclassification of assets from realizable assets to fixed assets
- Tax documents to be issued by sellers of used movable goods
- New instructions on the donation regime to non-profit entities
- Updated list of large taxpayers
- Issuance of invoices by supermarkets and restaurants
- Daily penalty interest rate for the first semester of 2025