The newly approved law Nº 20.630 has brought about several reforms of the Chilean tax legislation, raising, for example, the corporate tax rate to 20%, assimilating the cost of the limited liability companies’ (LLC) capital interests with that of the corporations’ stocks, unifying the taxation of the non-deductible expenses, and, including, as a great novelty, a new article 41E to the Income Tax Law, containing the new Chilean regulation on transfer pricing. Marcelo Muñoz Perdiguero, of Salcedo y Cia, explores the new measures.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default