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Chile Issues Circular on Activation of Interest and Royalties MFN Clauses in Tax Treaties with Austria, China, Ecuador, and Spain

18 October 2018

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Treaty Development

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Chile-Austria-China-Ecuador-Spain

The Chilean tax authority (SII) has issued Circular No. 50 of 11 October 2018 concerning the activation of the MFN clauses with respect to interest and royalty income under Chile's tax treaties with Austria, China, Ecuador, and Spain as a result of Chile's 2016 tax treaty with Japan. Interest Income With respect to the 2012 tax treaty with Austria, the 1999 tax treaty with Ecuador, and the 2003 tax treaty with Spain, the Circular provides that the following withholding tax rates apply as from 1 January 2017 with respect to interest income: The rate is 4% where the beneficial owner...