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Chile Clarifies Application of Thin Capitalization Rules

|Approved Changes|Chile
Chile

The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 1475 of 31 July 2020 concerning the scope of loan agreements subject to the application of the thin capitalization rules under Article 41 F of the Chilean Income Tax Law, which was introduced as part of Chile's 2014 tax reform (Law No. 20.780). In particular, the ruling addresses whether interest payments on a loan agreement concluded in 2014 between a Chilean resident company and a non-resident r…

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