The Chilean Internal Revenue Service (SII), through Official Ruling No. 2,670, clarified the tax treatment of dividends distributed to foreign investors through international custodians. The exemption under Article 63 of the Income Tax Law applies only to the beneficial owner who is resident in a country with a tax treaty in force. The ruling also addresses refunds arising from undue restitutions and the burden of proof borne by the responsible agent.

The Chilean Internal Revenue Service (SII), through Official Ruling No. 2,670, clarified the tax treatment of dividends distributed to foreign investors through international custodians. The exemption under Article 63 of the Income Tax Law applies only to the beneficial owner who is resident in a country with a tax treaty in force. The ruling also addresses refunds arising from undue restitutions and the burden of proof borne by the responsible agent.