The tax administration has issued Ruling 604 of 25th February 2015 that describes income tax treatment derived by non-residents from bonds and other debt instruments. Article 1 of Law 20, 780 to article 11 of income tax law has introduced amendments by which this tax treatment is clarified. The SII has ruled that capital gains derived by non-residents from the alienation of bonds and other debt instruments issued by resident companies in foreign markets are not Chilean-source income, and so non-residents are not paying tax with respect to this income. Again, the basis of interest is considered to be in the domicile of the debtor, and so that interest is Chilean-source income and for this reason, interest from bonds and other debt instruments issued by resident companies in foreign markets are subject to tax in Chile.
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