Treaty between Chile and Spain – Chilean clarification on PE concept
The tax administration (SII) issued the Ruling (Oficio) No. 3,397 of 14 December 2007 clarifying the concept of permanent establishment (PE) and the taxation of payments made by a Chilean company to its Spanish parent for services rendered by four employees who will work in Chile. The main issues are summarized below.
Under Art. 5 Para. 3(b) of the Chile-Spain tax…
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