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Services provided between a branch and its head office

01 March 2011


Sandra Benedetto B Sharoni Rosenberg A

Ruling no. 2438, issued by the Chilean Internal Revenue Service (Chilean IRS) on December 28 2010, refers to an issue that has been uncertain for Chilean taxpayers for a long time. The discussion centres on whether a branch can or cannot provide services to its head office and vice versa.

On one hand, the Chilean IRS issued rulings that said that a branch of a foreign company does not constitute a different legal entity from the latter, and that it shares the same legal personality as its head office, a...



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