In a public ruling Oficio No 1338 of 04 July 2024, the Chilean Revenue Service (SII) clarified its position with respect to the question as to whether Chilean investment and mutual funds are eligible for the benefits of the reduced dividend withholding tax rate under the Chile-USA tax treaty. The SII recalled the basic principle that for a person to qualify for treaty benefits, that person must first qualify as a person and a resident of one of the Contracting States and must subsequently pass any LoB tests included in the relevant treaty. In this respect, the combination of Art....