In recent years, the number of enquiries received by the Chilean tax authority regarding the impact in Chile from international and cross-border reorganisations has grown exponentially, write Santiago López and Stephanie Chacra of PwC Chile. Indeed, in past international updates we have reported how the Chilean IRS has been formulating uniform criteria for this purpose.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap