The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 757 of 8 March 2022 concerning the control conditions for the application of the controlled foreign company (CFC) rules. The letter ruling is in response to a question on whether the control condition is met in a case where a Chilean resident holds exclusive administration rights in a foreign company but does not hold more than 50% of the shares in the company. There are three other shareholders i…