Chile has published Ruling No. 2622 of 16 October 2019, which clarifies the tax treatment of software distribution rights under the 2004 tax treaty with France. The ruling concerns a Chilean company acting as a commercial intermediary under an agreement with a French company for the resale of software in Chile. Under the agreement, the Chilean company acquires the software at a set price for resale to end users and is not granted any other rights in relation to the software IP, which are kep…