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Chilean IRS clarified definition and application of PE concept under Chile-Peru treaty

|Treaty Development|Chile-Peru
Chile-Peru

The Chilean Internal Revenue Service gave a decision in Ruling 2890 of 4 August 2005, in which it clarified the definition and application of the permanent establishment (PE) concept under tax treaty between Chile and Peru.

Taxpayer put forward the situation of Peruvian domiciled enterprises furnishing services to Chilean enterprises. The services are wholly carried out in Peru, excep…

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