The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 711 of 10 April 2025 concerning the taxation of payments for technical services under the 2007 Chile-Colombia tax treaty. The letter concerns two Colombian individuals providing remote software development services to a Chilean company, with no employment relationship between the parties. The letter confirms that payments for such services are subject to 15% withholding tax under domestic law assuming that the services qualify as technical services. However, the letter also confirms that such services would be covered under Article 12 (Royalties) of the 2007 tax...