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Chile releases new regulations for neutral tax reorganization regime

04 April 2025

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Tax Alerts, National/Federal Taxation, G...

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Chile

On 27 March 2025, Chilean Tax Authorities issued new regulations for domestic and foreign reorganizations under a tax neutrality regime, including new restrictions for deemed tax-haven jurisdictions.These new regulations follow the changes made in the tax compliance bill (Law No. 21,713), which came into force as of 1 November 2024.Although the new regulations provide valuable guidance to navigate these changes, further developments resulting from specific rulings on a case-by-case basis are anticipated. On 27 March 2025, the Chilean Tax Authorities issued new regulations in Circular No. 23, addressing the tax-neutral regime for domestic and foreign reorganizations and the prerogative to evaluate...