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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