Chile’s Internal Revenue Service (Servicio de Impuestos Internos, SII) recently issued Official Ruling No. 143/2026, clarifying how tax valuation powers apply to the contribution of shares of a Chilean company into a newly formed holding company. In the situation analyzed, shareholders planned to transfer their shares to a newly established Chilean holding company while maintaining their ownership proportions. The SII confirmed that its valuation powers (“facultad de tasación”) will not be applied to revalue the contributed shares as long as the transaction has a legitimate business purpose, no cash distribution occurs, and the tax cost of the assets is preserved in the receiving company. This clarification provides certainty for corporate restructurings and outlines the circumstances under which the SII refrains from exercising valuation powers in non-cash reorganizations.
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