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Chilean Tax Authority Clarifies Control Requirements for Exception from Taxation of Indirect Disposal of Underlying Assets in Chile

|Approved Changes|Chile
Chile

The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 1154 of 19 June 2025 in response to a query concerning the taxation of the indirect disposal of underlying assets in Chile by an Australian business group. The transaction involves the transfer of 100% of a holding company incorporated in the British Virgin Islands (BVI) by another BVI company, the sole shareholder of which is a discretionary trust governed by the laws of Jersey. The beneficiaries…

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