Chile Clarifies Availability of Foreign Tax Credit for Dividends Received in Chile through a Foreign Intermediary

The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Official Letter No. 2625 of 16 October 2019 concerning whether a resident of Chile may receive a foreign tax credit for U.S. tax withheld on dividends paid by a U.S. subsidiary and received through an intermediary resident in a third country. The case involves a legal entity incorporated in Chile that will invest in a foreign intermediary that will invest in U.S. subsidiaries, holding 10% or more of the capital in …