The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 2411 of 9 September 2021 on its website regarding the taxation of dividends under the 2003 Chile-Spain tax treaty. The ruling addresses a question from a Spanish taxpayer regarding the refund of perceived excess tax paid on dividends received from a Chilean company.
The ruling explains that, although Article 10 (Dividends) provides for a general withholding tax rate of 10% on dividends (5% if 20…