US-Chile Treaty Builds Tax Certainty for MNEs with MAPs and APAs

On December 19, 2023, the US-Chile income tax treaty entered into force. Pursuant to this treaty, MNEs can now use US-Chile mutual agreement procedures and bilateral advance pricing agreements to prevent double taxation and achieve more tax certainty. Given the increase in audit activity in Chile—which is expected to continue going forward—this is a welcome advance for MNEs. For the US, the US-Chile treaty is only the second US comprehensive bilateral tax treaty in force with a South American country—and is the first new comprehensive bilateral tax treaty signed by the US to enter into force in over ten years. ...