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Chilean appeals court considers whether Chile can tax Spanish resident's indirect transfer of Chilean company

|Tax Alerts, National/Federal Taxation, Treaties|Chile, Spain
Chile, Spain
  • The Chilean Court of Appeals has held that Chile may not tax a Spanish resident's indirect transfer of a Chilean company.
  • The Chilean Internal Revenue Service (IRS) asserts that Chile may tax both direct and indirect transfers under the Double-Tax Treaty between Chile and Spain.
  • It is unclear whether the Chilean IRS will appeal the court's decision.

On 14 April 2023, the Court of Appeals of Santiago, Chile, issued a ruling of special relevance, concluding that, under the terms of the Double-Tax Tre…

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