Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary.
Chile’s tax administration (SII) issued Ruling No. 1500-2025 on 7 August 2025, clarifying that Chilean resident individuals receiving dividend income from a foreign subsidiary of a controlled foreign company (CFC) are eligible to claim an indirect foreign tax credit.
This credit applies to taxes paid by the subsidiary in the source country.
Ruling No. 1500-2025 clarifies that Chile grants an indirect foreign tax credit on dividend income if a valid tax treaty or information exchange agreement exists with the subsidiary’s country, and the controlled foreign company holds (directly or indirectly) at least 10% of the subsidiary’s capital.
Earlier, the tax authorities issued Circular Letter 11/2025 on 30 January 2025, which establishes controlled foreign company (CFC) regulations in Chile.
