On December 3, 2025, the Chilean Internal Revenue Service (Servicio de Impuestos Internos – SII) issued Ruling No. 2507 regarding the dissolution and liquidation of a company incorporated abroad.
The taxpayer’s query concerned two individuals who inherited shares in a foreign company and asked whether, upon dissolution and allocation of assets, the excess value of the assets received over their tax cost should be recognized as taxable income in Chile.
The the Chilean Internal Revenue Service stated that the allocation of assets resulting from the liquidation of a company does not constitute taxable income insofar as the total value received does not exceed the contributed capital. Any excess, however, constitutes taxable income subject to Chilean corporate tax and final taxes.
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Claudia Valdés Muñoz cvaldes@bbsc.cl +56 9 8139 3599
