Chile: Tax treatment of corporate reorganization involving capital contribution followed by redemption; other tax developments

Ruling No. 2026/2026 clarified the tax treatment of a proposed corporate reorganization involving a contribution of assets to a Chilean company by a Swedish company equal to the tax basis that a Mexican company has in the shares of the Chilean company, followed by a redemption of the Mexican company.

The tax authority ruled that the Swedish’s company’s contribution could be excluded from appraisal as a domestic business reorganization, provided it involves assets located in Chile and the other applicable requirements are met. As to the redemption of the Mexican company, the tax authority clarified that it does not, by itself, constitute a reorganization, although it may form part of a sequence of transactions that viewed as a whole, has that character. In such case, appraisal will not apply when the tax basis of the assets is maintained, no cash flows arise for the contributor, the requirements of the foreign jurisdiction are met, there is a valid business purpose, and Chile's taxing rights are not impaired.

Read a September 2026 report prepared by the KPMG member firm in Chile

Other tax-related developments discussed in this report include:

• New annual sworn statement for digital platform operators
• Withdrawals of fully taxed income charged against the Register for Exempt Income (REX)
• Taxation of stablecoin transactions
• Updated guidance on the Review of Audit Actions (RAF), Voluntary Administrative Reconsideration (RAV), and hierarchical appeal