The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Ruling 1522 of 3 June 2019, concerning the availability of a foreign tax credit for a professional partnership in Chile that received fees for services provided to a company in Brazil, on which tax was withheld. The ruling provides that under the terms of the 2001 tax treaty with Brazil, the partnership itself would not qualify as a resident of a Contracting State because, due to its pass-through nature, it is not …