The Chilean tax authority (SII) has published Ruling No. 1984 of 26 July 2019 concerning the application of the 2015 tax treaty with Argentina for interest paid in relation to a loan agreement entered into in 2019 between an Argentinian parent and its wholly-owned subsidiary in Chile. The loan was provided to fund financing of an unrelated third party. The Ruling provides the following to clarify the application of the treaty:
- First, it must be determined whether the payments are in the nat…