International Tax 2026

CHILE Law and Practice Contributed by: Javier Cortés, Juan Pablo Márquez and Gonzalo Pérez, Cortés Del Río Tax & Legal

Cortés Del Río Tax & Legal Alonso de Córdova 5151 Office 1004 Las Condes Santiago Chile Tel: +569 93182041 Email: jcortes@cortestaxlegal.com Web: www.cortestaxlegal.com

1. Sources and Principles 1.1 Domestic Sources of International Tax Law The main domestic sources of international tax law in Chile are: the Chilean Constitution, which sets forth certain principles regarding taxation, guarantees indi - vidual’s economic rights and states that the exercise of sovereignty recognises as a limitation respect for the essential rights that emanate from human nature, as guaranteed by the Constitution and international treaties ratified by Chile that are currently in force. Additionally, there are several tax laws which refer to different kind of taxes, such as the Income Tax Law (ITL), Tax Code, VAT Law, Stamp Tax Law and Real Estate Tax Law, among others. These instruments are supplemented by a wide range of special laws which include tax provisions, as well as certain regulations enacted by the executive branch to implement laws. In addition, the Chilean tax authority (“Chilean IRS”) issues: • circulars which are interpretations of general appli - cation; • resolutions aimed at regulating matters of an administrative nature; and • specific rulings ( oficios ) which are binding opinions issued in response to specific taxpayer queries. While these instruments are formally binding only on the Chilean IRS officials, they carry considerable prac - tical weight and taxpayers routinely rely on them for

planning purposes. Academic commentary by schol - ars also contributes to the interpretation of principles of international taxation. Judicial precedents from the tax courts, the Courts of Appeals and the Supreme Court play a growing role in shaping Chilean domestic and international tax law. Although Chile does not formally apply the doctrine of binding precedent (stare decisis), Supreme Court rulings are highly persuasive in the lower courts and for taxpayers in general. Chile has an extensive treaty network comprising double taxation agreements (DTAs) with the follow - ing countries: Argentina, Australia, Austria, Belgium, Brazil, Canada, China, Colombia, Croatia, Czech Republic, Denmark, Ecuador, France, India, Ireland, Italy, Japan, Malaysia, Mexico, the Netherlands, New Zealand, Norway, Paraguay, Peru, Poland, Portugal, Russia, Spain, South Africa, South Korea, Sweden, Switzerland, Thailand, the UAE, the United Kingdom, the United States of America, and Uruguay. 1.2 Hierarchy of Sources The highest hierarchy of legal sources in Chile is the Constitution, followed by the tax laws in second place. International treaties ratified and enacted in accord - ance with the Constitution have the force of domestic law. In practice, treaty provisions offering more favour - able treatment to a taxpayer will take precedence over conflicting domestic rules.

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