Chile-Changes in requirements regarding derivative transactions between related parties
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In late 2012, the Chilean Tax Authorities (Servicio de Impuestos Internos or 'Chilean IRS') issued resolution No. 115, which states that taxpayers who celebrate derivative contracts with related parties, must have a Technical Memo, at the disposal of the Chilean IRS, containing the necessary elements to demonstrate that such contracts have been agreed under arm's-length conditions.
The rule is applicable to all those derivative contracts agreed with related parties during fiscal year 2012 or that have otherwise been amended during fiscal year 2012.
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