The tax authority (SII) has released Circular No. 31 of 23 May 2018. It assures the transition relief provided regarding dividends paid by taxpayers under the partially integrated regime (PIS). The tax authority has also published Ordinance 470 and Ordinance 471 of 5 March 2018. It describes the application of the dual corporate tax regimes introduced as of January 1, 2017. These regimes are the standard attribution regime (AIS regime) and the partially integrated regime (PIS regime).
This Circular states that under PIS regime, any Chilean companies paid dividends to non-residents got the transitional relief. So that, 65% limit would not apply conditioning that the treaty with Chile was signed before January 1, 2017 and will enter into force on December 31, 2019. This relief was prolonged by two years. That means, that 65% limit does not apply until the treaty is signed before January 1, 2019 and will come into force on December 31, 2021.
