Ruling on regional head offices of foreign companies

The Chilean tax authorities (SII) issued Ruling No. 52 on 4 October 2005, which has effect from 11 October 2005, regarding the establishment in Chile of regional head offices (Presidencias Regionales) of foreign companies.

According to the ruling, regional head offices established in Chile are not considered for tax purposes to give rise to permanent establishments in Chile. Accordingly, the activities carried out in Chile by such regional head offices are not subject to corporate tax in…