Chile Clarifies Royalty Deduction Restriction Under Tax Treaty with Denmark
The Chilean tax authority (Servicio de Impuestos Internos - SII) recently published Letter Ruling No. 477 concerning the domestic restriction on the deduction of royalty payments to non-resident parties as it applies in relation to the provisions of the 2002 Chile-Denmark tax treaty. The restriction generally limits the deduction of royalty expenses to 4% of receipts from sales or services, alt…
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