Chile’s general anti-avoidance rule debuted in Forestal Aurora SpA v Servicio de Impuestos Internos, the first Chilean judicial ruling on the GAAR. Former President Michelle Bachelet enacted the Chilean GAAR in 2014. Since then the Chilean tax administration, or SII, opted to create a catalog of 85 operations potentially subject to the GAAR and has reviewed over 94 requests of opinion into whether certain “hypothetical transactions” could be called into question under the rule.
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