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Netherlands: Clarification regarding tax classification of Chilean SpA

Chilean Sociedad por Acciones (SpA) is comparable to a Dutch NV or BV for Dutch tax purposes

July 28, 2026

The Dutch tax administration Knowledge Group on June 30, 2026, published position KG:211:2026:20, concluding that a Chilean Sociedad por Acciones (SpA) is comparable to a Dutch public limited company (NV) or private limited company (BV) for Dutch corporate income tax (CIT), individual income tax, dividend withholding tax, and conditional withholding tax purposes.

The position states that the Chilean SpA has legal personality, share capital, limited shareholder liability, governing bodies, and articles of association, and therefore aligns with the key characteristics of Dutch capital companies despite certain differences, such as the inability to be publicly listed.


For more information, contact a KPMG tax professional in the Netherlands:

Paul te Boekhorst | teboekhorst.paul@kpmg.com

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