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12/19/2023

Treasury Announces Entry into Force of Income Tax Treaty with Chile | U.S. Department of the Treasury

Treasury Announces Entry into Force of Income Tax Treaty with
Chile
December 19, 2023

WASHINGTON – The U.S. Department of the Treasury today announced the entry into force of
a comprehensive income tax treaty between the United States and Chile. The Chile tax treaty
is the first new comprehensive bilateral tax treaty signed by the United States to enter into
force in over ten years. The Chile tax treaty will reduce tax-related barriers to cross-border
investments between the United States and Chile and is only the second U.S. comprehensive
bilateral tax treaty in force with a South American country. The Chile tax treaty was approved
by an overwhelming majority in the U.S. Senate on June 22, 2023, and President Biden signed
the instrument of ratification in December. The treaty entered into force today when the
United States notified Chile that it had satisfied its applicable procedures for bringing the
treaty into force.
Provisions in the Chile tax treaty include:
Reduced source-country withholding tax on certain payments of dividends as well as
payments of interest and royalties.
A prohibition against source-country taxation of business profits of an enterprise in the
absence of a so-called “permanent establishment.”
Beneficial rules for individuals, including provisions that govern the taxation of income
from employment, payments to students and trainees, and pensions and social security
payments.
A comprehensive limitation on benefits provision.
A comprehensive provision allowing for full exchange of information between the U.S. and
Chilean tax authorities.
With respect to taxes withheld at source, the Chile tax treaty will have e ect for amounts paid
or credited on or a er February 1, 2024. For all other taxes, the Chile tax treaty will have e ect
for taxable periods beginning on or a er January 1, 2024.
To access the documents related to the treaty, click here.
https://home.treasury.gov/news/press-releases/jy2003

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12/19/2023

Treasury Announces Entry into Force of Income Tax Treaty with Chile | U.S. Department of the Treasury

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https://home.treasury.gov/news/press-releases/jy2003

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