The Chilean tax authority (Servicio de Impuestos Internos - SII) recently published Letter Ruling No. 477 concerning the domestic restriction on the deduction of royalty payments to non-resident parties as it applies in relation to the provisions of the 2002 Chile-Denmark tax treaty. The restriction generally limits the deduction of royalty expenses to 4% of receipts from sales or services, although the restriction does not apply if the non-resident is unrelated to the Chilean payer or the ro…