Chile-Changes in requirements regarding derivative transactions between related parties

Tax Insights ()

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.