Chile Tax Agency Clarifies Taxation of Financial Advisory Services Under 2021 DTA, Protocol With Netherlands

The Chilean Internal Revenue Service Feb. 13 issued Letter No. 343, clarifying the taxation of advisory services provided to a nonresident company under the 2021 DTA and protocol with the Netherlands. The taxpayer, a Chilean investment company, provided financial advisory services to a Dutch bank. The taxpayer sought confirmation regarding whether the services were exempt from additional tax under the 2021 DTA with the Netherlands or as a commercial commission, and whether the payments were subject to VAT. The Tax Agency clarified that: 1) the taxpayer’s services couldn’t be treated as a commission because they constituted financial advice; 2) payments ...