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The Chile-India double taxation treaty was signed on March 9th, 2021 and entered into force on January 1st, 2023.
The maximum withholding tax rates are:
– | 10% on dividends. Notwithstanding the above, the treaty contains the “Chile clause”, according to which Chile will be entitled to withhold the full 35% rate of its local withholding tax on dividends, insofar as Chilean legislation acknowledges a tax credit consisting of the full corporate taxes paid by the distributing entity; |
– | 10% on interest; |
– | 10% on royalties; |
– | 10% on technical services; and |
– | Regarding capital gains, they may generally be taxed in either of the two Contracting States. In the case of shares or other rights representing capital, there will be no taxation at source if, at any time during the 365 days prior to the alienation, the shares derived 50% or less of their value directly or indirectly from immovable property, situated in the other State. |
The treaty does not contain a most-favored nation clause.
The treaty also contains a limitation on benefits (LOB) provision under which treaty benefits are granted to qualified persons and residents deriving business income from the active conduct of a business. Not regarded as active business activities are pure holding activities without substance, as group financing (including cash pooling), making or managing investments, unless these activities are carried out by a bank, insurance enterprise or registered securities dealer in the ordinary course of its business. Treaty benefits will not be granted if obtaining those benefits was one of the principal purposes of any arrangement or transaction. Conversely, the respective Tax Administration may grant treaty benefits to non-qualified persons if the respective taxpayer demonstrates to the former’s satisfaction that neither its establishment, acquisition, or maintenance, nor the conduct of its operations, had as one of its principal purposes the obtaining of benefits under the agreement. The profits that the state where an enterprise is established allocates to a third country PE will only be entitled to treaty benefits if the tax rate in the third country is at least 60% of the tax that would be imposed on those profits in the state where the enterprise is established.