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Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.
Over the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.
Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.
