Chile
Recent Court of Appeals decision on indirect transfers and taxation under the Double Taxation Agreement with the US.
In Chile a 35% tax is applied on the capital gain realized by a non-Chilean resident taxpayer from the sale of shares, equity rights and ownership interests, in an entity also incorporated abroad, but that has underlying assets (e.g., shares) located in Chile, to the extent that such assets represent or have a substantial value. In other words, Chile taxes capital gains realized from indirect transfers when certain value thresholds are exceeded.