Emerging Markets Rates and Currencies Handbook

77 Citi | Emerging Markets Currencies Handbook 2021 Chile Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 35% WHT unless FI 4% WHT if FI and D/E < 3 4% WHT 35% WHT if D/E > 3 (non applicable for banks/FI as borrowers) No WHT Onshore: No WHT Offshore: Compensation: none Others: premium, fees = 35% 35% WHT on dividends 35% WHT on capital gain No WHT on sale of listed shares Deductibility of interests Interest is deductible, unless D/E > 3x (**) Fully deductible Fully deductible N/A Deductibility of FX losses Fully deductible Fully deductible Fully deductible N/A Other taxes, duties Stamp Tax 0.066% per month, cap 0.80% flat Demand Loan Duty of 0.332% if no defined maturity date N/A N/A Comments N/A Collateralized loans are subject to the thin cap rule (D/E > 3) N/A N/A N/A (** ) D/E > 3 with following rules: (1) The 3:1 debt-to-equity limit would be tested on the aggregate of related-party and third-party debt (2) The 3:1 debt-to-equity limit would be tested annually, (every year during the loan) (3) The 35% surtax is levied, in addition to interest, on all charges and fees linked to excessive-indebtedness Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources. Subsidiary Funding — Tax Consideration Tax Summary — Chile