Chile: Consultation on appointment of representative of business groups; other direct and indirect tax developments
Summary of recent direct and indirect tax developments
The tax authority (SII) initiated a consultation regarding the obligation of business groups to appoint a common representative in the following cases: (1) a group with a single subsidiary in Chile whose parent or controlling company is abroad; and (2) a group with a number of entities in Chile, without a common holding company in Chile, all controlled by a foreign parent company.
Regarding the first case, the SII proposes that if the entity domiciled in Chile is the only subsidiary of the group in the country, it can appoint the attorney-in-fact, informing its own data as the only local member of the business group. On the other hand, in the case of several local entities belonging to the same business group and controlled by their foreign parent company, the group may choose only one of them to designate the common attorney-in-fact, identifying all the entities that are part of the group in Chile and indicating their respective percentages of direct and indirect participation of the foreign parent company.
Read a June 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:
- Situation of the United Arab Emirates (UAE) and Costa Rica as preferential tax regimes
- Payment of the sale price of shares subject to a condition
- Application of general anti-avoidance rule (GAAR) in the event of a split and merger
- Provisions for loans included in non-performing loans of banks and financial institutions
- Execution of a guarantee slip
- Value added tax (VAT) on the sale of copper concentrate intended for export