On 8 May 2015, Chile's Internal Revenue Service published Circular No. 30, which provides guidance on new rules regarding the treatment of passive income of controlled foreign companies. The new rules are included under Article 41 G of the Chilean Income Tax Law, which was introduced with Chile's 2014 tax reform and applies from 1 January 2016.
Under Article 41 G all taxpayers domiciled, resident, or incorporated in Chile that have direct or indirect control over foreign entities must treat …