Chile Clarifies Availability of Foreign Tax Credit for Taxes Not Covered by Tax Treaty

The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 369 of 14 February 2025 concerning the availability of a foreign tax credit for foreign taxes not covered by a tax treaty. In particular, the letter addresses the question of whether a credit is available in respect of U.S. state taxes levied on income from the provision of technical assistance services. The letter confirms that such taxes are not covered by the Chile-U.S. tax treaty, which only c…