Daily Tax Report: International

Chile Tax Agency Clarifies Taxation of Dividends Obtained Through Intermediary

Oct. 18, 2019, 6:27 PM

The Chilean Internal Revenue Service Oct. 16 issued a letter clarifying the tax treatment of taxes paid on dividends received indirectly through a nonresident intermediary. The taxpayer is a Chilean corporation that invested in a nonresident company, which invested in a U.S. subsidiary. The taxpayer was taxed by the U.S. and Chile on dividends received indirectly from the U.S. subsidiary. The letter explained that to receive tax credits for dividends received from a nonresident intermediary, the subsidiary must be domiciled: 1) in the same country as the nonresident intermediary; or 2) in a country that has signed a DTA or...

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