Chilean IRS clarified definition and application of PE concept under Chile-Peru treaty

The Chilean Internal Revenue Service gave a decision in Ruling 2890 of 4 August 2005, in which it clarified the definition and application of the permanent establishment (PE) concept under tax treaty between Chile and Peru.

Taxpayer put forward the situation of Peruvian domiciled enterprises furnishing services to Chilean enterprises. The services are wholly carried out in Peru, except in some cases when personnel is sent to Chile for periods that may exceed 183 days. Taxpayer req…