Chile has 33 tax agreements in force, as reported in its response to the Peer Review questionnaire. Five of those agreements, the agreements with Argentina, China, Italy, Japan and Uruguay, comply with the minimum standard.

Chile signed the MLI in 2017, listing 33 tax agreements.1

Chile is implementing the minimum standard through the inclusion of the preamble statement and the PPT combined with the LOB. For its compliant agreements with Italy and Japan, the minimum standard is implemented through the inclusion of the preamble statement and the PPT.2 Chile notes that all of its agreements that do not contain a PPT provision include a main purpose test in the dividends, interest and royalties articles.

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

No jurisdiction has raised any concerns about their agreements with Chile.


← 1. In total, Chile listed 34 agreements under the MLI, one of which (the agreement with the United States) is not yet in force. The agreements with Argentina, China, Italy, Japan and Uruguay are already compliant and were listed under the MLI.

← 2. For 28 of its agreements listed under the MLI, Chile is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Chile also opted for the simplified LOB under Article 7(6) of the MLI and expressed a statement that while Chile accepts the application of the PPT under the MLI, it intends where possible to adopt an LOB provision through bilateral negotiation. Chile made a reservation pursuant to Article 6(4) not to apply Article 6(1) with respect to agreements, which already contain the relevant preamble language. Chile also made a reservation pursuant to Article 7(15)(b) not to apply Article 7(1) with respect to agreements which already contain a PPT. Five of Chile’s agreements are within the scope of these reservations.

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