US and Chile Sign New Income Tax Treaty on 2/4/10

WASHINGTON – In a ceremony at the U.S. Department of the Treasury today, Treasury Secretary Tim Geithner and Chilean Finance Minister Andrés Velasco signed a new income tax treaty between the United States and Chile that would provide certainty and stability of tax treatment for U.S. and Chilean cross-border investors.

If approved by the U.S. Senate, this treaty would be the first bilateral income tax treaty between the United States and Chile and would be only the second U.S. tax treaty with a South American country.

Provisions of the new tax treaty with Chile include:

Reductions in source-country withholding taxes on certain cross-border payments of dividends, interest and royalties;
Rules to determine when an enterprise or an individual of one country is subject to tax on business activities in the other country; and

Rules to enhance the mobility of labor by coordinating the tax aspects of the U.S. and Chilean pension systems.

The new tax treaty also contains other important provisions, including mechanisms through which the U.S. and Chilean tax authorities may collaborate to resolve tax disputes and relieve double taxation; provisions to ensure the full exchange between the U.S. and Chilean tax authorities of information for tax purposes; protections against discriminatory tax treatment; and provisions to ensure that only residents of the two countries enjoy the benefits of the treaty.