Emerging Markets Rates and Currencies Handbook

Tax Summary – Chile Chile Deductibility of FX Losses • Fully deductible • N/A Other Taxes/Duties • Stamp Tax 0.066% per month between grant and maturity date, cap 0.80% flat over the principal. Demand Loan Duty of 0.332%. • N/A • N/A Comments • Structured agreement corresponds to such that a foreign or international banking or financial institution receives interest and transfers it to another person or entity that is domiciled or resident abroad, and that it would not be entitled to the reduced rate if it had directly received the interest from debtor. • Collateralized loans are subject to the thin cap rule (D/E > 3)** • , as long as: • (1) The loan is guaranteed by a related party • (2) Those who guarantee the loan are non- residents or domiciled in Chile • (3) Those who guarantee the loan are the final beneficiaries of the interests. • N/A • N/A • N/A • Fully deductible • Fully deductible to the extent they relate to income generating activities • Fully deductible • Capital gains loss can be deducted by local taxpayers or compensated against income of same nature in other cases. • Since September 1st losses derived of listed shares sales can be deducted (** ) D/E > 3 with following rules: (1) The 3:1 debt-to-equity limit would be tested on the aggregate of related-party and third-party debt. (2) The 3:1 debt-to-equity limit would be tested annually, (every year during the loan). (3) The 35% surtax is levied, in addition to interest, on all charges and fees linked to excessive-indebtedness. WHT that levied such interest is credit against the surtax. The surtax is credit for the Chilean taxpayer debtor. Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available source Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing