Chilean Senate Approves Protocol to Tax Treaty with Brazil

On 15 November 2023, the Chilean Senate (upper house of Congress) approved the ratification of the pending protocol to the 2001 tax treaty with Brazil. The protocol, signed 3 March 2022, is the first to amend the treaty and includes the following main changes:

• The title and preamble are replaced in line with OECD BEPS standards;
• Article 1 (Personal Scope) is replaced, including the provision that income derived by or through an entity or arrangement that is treated as wholly or partly fiscal…