Foreign investors that use pass-through investment vehicles may not completely credit the payment of corporate income tax against the dividend withholding tax, unless the investors may claim residence for purposes of applying a double tax treaty (DTT).
On 9 December 2020, the Chilean tax authorities issued Resolution Ex. No. 151 of 2020 (the Resolution), which includes regulations for foreign investors that use pass-through investment vehicles located in countries that have DTTs in force wit…