1. REGIME COMPARISON Regime “A” Regime “B” Effective Distribution
Regime A Company
$100
25%
$25
Net taxable income
CT rate* CT
$100
27%
$27
Regime B
Company
Effective
Distribution
Attribution
100%
Property
100% Credit
65% Credit
100%
Property
$100
35%
$35
($25)
$10
WHT or GCT tax base
WHT or GCT tax rate*
WHT or GCT
CT Credit
Amount to be paid
$100
35%
$35
($17.55)
$17.45
Regime “A”: Effective income regime according to full accounting records, with a full Corporate Tax (“CT”) imputation as credit against the final taxes, established in letter A) of Article 14 of the ITL, also named “Attributed Income”.
Regime “B”: Effective income regime according to full accounting records, with partial CT imputation as credit against the final taxes, established in letter B) of Article 14 of the ITL, also named “Semi-integrated”.
During 2016, the CT rate will be 2016 for both regimes. From 2017 onwards, the applicable rate for taxpayers subject to Regime A will be 25%. The CT rate applicable to taxpayers subject to Regime B will be 25.5% during 2017 and 27% from 2018 onwards.
The applicable final tax will be: (1) Global Complementary Tax (“GCT”) if the shareholder is a taxpayer domiciled or resident in Chile, or (2) Withholding Tax (“WHT”) if the shareholder is a taxpayer NOT domiciled nor resident in Chile. The GCT is a progressive tax which maximum rate will be 35% from 2017 onwards.

2. COMPARISON SHAREHOLDER RESIDENT IN A TAX TREATY VS
COMPARISON SHAREHOLDER RESIDENT IN A TAX TREATY VS. NON-TAX TREATY JURISDICTION
Shareholder Resident in a Non-Tax Treaty Jurisdiction
Operating Company
Net Taxable Income
100
Corporate Tax (27%)* 27
Remaining 73
Profits for Distribution
Holding
Received Dividends
Taxables
Corporate Tax (27%)
Credit (27%)
Tax Due
Foreign Company / Shareholder
Distributed Dividends
Gross Up (+ 27)
Withholding Tax (35%) 35
Credit (27%*65%)
(18) 17
Received Dividend 56
Total Tax Burden = 44.45%
Shareholder Resident in a Tax Treaty Jurisdiction
Operating Company
Net Taxable Income
100
Corporate Tax (27%)* 27
Remaining 73
Profits for Distribution
Holding
Received Dividends
Taxables
Corporate Tax (27%)
Credit (27%)
Tax Due
Foreign Company / Shareholder
Distributed Dividends
Gross Up (+ 27)
Withholding Tax (35%) 35
Credit (27%*100%)
(27) 8
Received Dividend 65
Total Tax Burden = 35%
Distribution
OFF SHORE
CHILE
Holding
Distribution
Operating Company 2
* The Regime B Corporate Tax rate will be 25.5% during and 27% from 2018 onwards.

3. REGIME “A”
Partners are exclusively individuals domiciled or resident in Chile
Partners are exclusively taxpayers not domiciled nor resident in Chile
Partners are exclusively individuals domiciled or resident in Chile and/or taxpayers not domiciled nor resident in Chile
CHILE
FOR.
FOR.
CHILE
FOR.
CHILE
CHILE
CHILE
CHILE
CHILE
CHILE
FOR.
CHILE
CHILE
CHILE
CHILE
CHILE
CORPORATION

4. REGIME “B” CHILE CHILE FOR. FOR. FOR. CHILE CHILE CHILE CHILE CHILE
CORPORATION

5. Tax Imputation Rules applicable to Withdrawals
in Attributed Income Regime (*)
Tax Imputation 1° 2° 3° 4° 5°
Registry
RAP
FUF
REX
N/A
Description
Own attributed taxable income (1) (3)
Differences between accelerated depreciation and normal depreciation, including FUF balance at December 31, 2016 (2)
1° Income exempt from GCT or WHT (own or from others), including FUNT balance as of December 31, 2016 (3)
2° Non taxable income (own or from others) including FUNT balance as of December 31, 2016 (3)
Not imputed to any registry (2)
Adjusted social capital (4)
Exempt from final taxes (GCT or WHT)
Subject to final taxes (GCT or WHT)
(*) Withdrawals in the Attributed Income Regime define their taxation at the end of the year in which they occur.
These profits were already subject to taxes at the moment of their attribution. Therefore, the effective withdrawal of the same is not subject to taxation.
In case of withdrawals, remittances or distributions subject to final taxes, taxpayers may use the credits to which they are entitled, which are accumulated in the balance of credits; If there are no credits left, the transitional rules of the Tax Reform also allow to use the credits associated to the historical FUT. Both types of credits are part of the SAC Registry. If withdrawals, remittances or distributions are perceived by an individual entrepreneur (Corporate Tax taxpayer), these are incorporated into his NTI.
If they are perceived by an individual entrepreneur (Corporate Tax taxpayer), they are incorporated to REX Registry.
Only applicable in case of capital reduction. These amounts are exempt from taxation provided that they do not correspond to capitalized profits subject to taxes.

6. Tax Imputation Rules applicable to Withdrawals
in Semi Integrated Regime (*)
Tax Imputation 1° 2° 3° 4° 5° 6°
Registry
RAI
FUF
REX
RAI/FUF/REX
(at the end of the business year)
N/A
Description
Taxable income, including the FUT balance as of December 31, 2016 (1)
Differences between accelerated depreciation and normal depreciation, including FUF balance at December 31, 2016 (1)
1° Income exempt from GCT or WHT (own or from others), including FUNT balance as of December 31, 2016 (2)
2° Non taxable income (own or from others) including FUNT balance as of December 31, 2016 (2)
“Provisional withdrawals” during the business year (4)
Amounts subject to taxation once withdrawn (1)
Adjusted social capital (3)
Exempt from final taxes (GCT or WHT)
Subject to final taxes (GCT or WHT)
(*) As a general rule, withdrawals in the Semi Integrated Regime define their taxation at the date of their occurrence.
In the case of withdrawals, remittances or distributions subject to final taxes, the credits to which they are entitled, accumulated in the balance of credits, can be used; If there are no credits left, the transitional rules of the Tax Reform also allow to use the credits associated to the historical FUT. Both types of credits are part of the SAC Registry. If withdrawals, remittances or distributions are perceived by a taxpayer of the Attributed Income Regime, these are incorporated into its NTI and in case they are perceived by a taxpayer of the Semi Integrated Regime, only the Corporate Tax credit will be registered in its SAC Registry.
If they are perceived by a Corporate Tax taxpayer, they are incorporated in the REX Registry.
Only applicable in case of capital reduction. These amounts are exempt from taxation provided that they do not correspond to capitalized profits subject to taxes.
They must be added to the tax capital for the purposes of calculating the RAI Registry at the end of each business year.

7. The content of this document is provided by Carey y Cía
*The content of this document is provided by Carey y Cía. For educational and informational purposes only and is not intended to be exact or complete, and should not be relied on as a substitute for legal advice. Carey y Cía. is not responsible for any consequences resulting from the action, lack of action or decision regarding the information contained in this publication.