Chile

Abstract

The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Chilean tax treaties Introduction Chile has twenty-four tax treaties currently in force and another three treatiesalready concluded awaiting parliamentary ratification. Furthermore, it is nownegotiating several tax treaties. Chile’s experience as a tax treaty partner is relatively recent. Its first taxtreaty was signed with Argentina in 1976 and entered into force in 1986. Thistreatyfollows the Andean Pact Model (1971). As of 1999, Chile became moreactive in negotiating andconcluding tax treaties mainly based on the OECD ModelTax Convention on Income and on Capital (OECDModel) and the United NationsModel Double Taxation Convention between Developed and Developing Countries (UNModel) with some differences derived from Chile’s particular tax system.The policy that Chile has followed in its tax treaty negotiations after signingits treaty with Argentina has been very consistent. Such policy has not beenmodified by the recent accession of Chile to the OECD, with the exception of theintroduction of the new standard on the exchange of information which has beenagreed in the recent treaties signed with Australia and the USA.