The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 641 of 27 March 2020 concerning the taxation of a foreign reorganization that involves the indirect transfer (sale) of Chilean assets. In general, the transfer of Chilean assets, including indirect transfers, may be subject to tax in Chile. The letter clarifies, however, that the indirect transfer of Chilean assets through the sale of shares in the context of a reorganization of a foreign business…