Chile Publishes Letter Ruling on Whether Administration Rights Constitute Control Under CFC Rules
The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 757 of 8 March 2022 concerning the control conditions for the application of the controlled foreign company (CFC) rules. The letter ruling is in response to a question on whether the control condition is met in a case where a Chilean resident holds exclusive administration rights in a foreign compan…
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