The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public until March 28, 2023.
The draft circular proposes that the 3-year time limit for taxpayers to file a MAP request commence from the business day following the initial notification of the action resulting in taxation not in accordance with the provisions of the double tax avoidance agreement.
Furthermore, the circular explains that the general rules on timelines, as stated in section 2.1.2 of Circular 13 of 2022, are applicable only in cases where the double tax treaty does not explicitly establish a computation rule concerning any timelines related to the MAP.
