New modifications only impact reporting duties
The Chilean IRS has issued Resolution 119/2020 (Resolution 119) and Resolution 11/2021 (Resolution 11) which provides further information regarding the indirect sale of foreign entities that indirectly own Chilean underlying assets (i.e. shares/quotas of a Chilean company, Chilean movable or immovable property, Chilean PE). The regulations became effective on January 1 2021.
The new resolutions modify the reporting rules that have been in effect since 2015 and established by Resolution 65/2015 (Resolution 65), regarding the indirect sale provision introduced by the Tax Reform of 2012 to our Income Tax Law.
Before reviewing these new obligations, it is important to bear in mind that the taxable event regarding the indirect sale of Chilean underlying assets has not been modified, these modifications only affect the reporting duties.