Chile Tax Agency Clarifies Taxation of Investment, Mutual Funds Under 2010 DTA, Protocol With U.S.

The Chilean Internal Revenue Service July 4 issued Letter No. 1338, clarifying the taxation of investment and mutual funds under the 2010 DTA and protocol with the U.S. The taxpayer sought clarification as to whether Chilean investment and mutual funds in the U.S. were eligible for the benefits of the reduced dividend tax rate under the Chile-U.S. DTA. The Tax Agency clarified that: 1) the DTA applies to resident entities of one or both contracting states, provided that the specified requirements pertaining to the limitation of benefits are satisfied; 2) the specified Chilean investment and mutual funds are not subject ...