DT4854 - Chile: Dividends

Chilean tax deducted from dividends paid by a Chilean company at the agreement rate of 15 per cent (5 per cent if the dividend is paid to a UK resident company which controls directly or indirectly at least 20 per cent of the voting stock of the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)). The reduction to the above rates is not given where the dividends are effectively connected with (see INTM153110, fifth sub-paragraph) a permanent establishment which the recipient has in Chile. Note DT 4851 with regard to the Additional tax paid at the time of distribution.

Where a dividend is paid to a UK resident company which controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividend, relief is also due under the agreement for underlying tax (see INTM164010(d) and Article 21(2)(b)).