Recent developments in the concept of a permanent establishment in Chile

International taxation is based on residence as the point of connection of a subject with a given territory. However, today’s world is characterized by open economies competing to attract many companies and governed by technology. Apart from the tax connection point represented by the tax domicile in a given country, another element relevant when taxing the income is the existence of a permanent establishment of a non-resident in that territory.

The ongoing growth of the internet has diminished the need for physical establishments to conduct business in another country. The tax connection point represented by a permanent establishment (PE) is undergoing mutations and expansions, making analysis increasingly complex. 

This article will review the provisions currently applicable in Chile concerning PE and look at the previous rules to understand the significant changes that have recently occurred in Chile in this area of tax rules governing cross-border transactions.