ES
ENLegislative update · Sources checked: 20 October 2026
Chile’s capital markets reform bill proposes changes for selected foreign investments and financing transactions. The practical starting point is to identify the activity: holding securities, financing a business or establishing a local operating presence.
What the bill could change for foreign investors
The Ministry of Finance describes a package covering financing, regulation and financial services. Proposed measures include a VAT exemption for certain financial services supplied from Chile to foreign clients, and broader stamp tax relief for qualifying foreign borrowing. Eligibility would depend on the final legislation and its conditions. Ministry of Finance announcement.
The proposed RUT exemption has a specific scope
Article four of the original bill would add an exception to Article 66 of Chile’s Tax Code for taxpayers without Chilean domicile or residence investing solely in instruments covered by Articles 104 and/or 107 of the Income Tax Law. RUT is the Chilean taxpayer identification number. Read the proposed provision on page 154.
This proposal does not establish a general route for incorporating a company, running a local business or acquiring any Chilean asset without a RUT. Establishing operations requires a separate review of the foreign entity, its Chilean vehicle and the intended activity.
For a current administrative example, the Internal Revenue Service explains that a foreign legal entity acquiring equity interests in a Chilean limited liability company obtains its RUT through a Chile-domiciled representative holding sufficient authority. SII guidance for that situation.
Three transactions to assess separately
| Transaction | What to review | Practical approach |
|---|---|---|
| Securities investment | Instrument, residence, custodian and proposed eligibility. | Check whether the portfolio falls within the proposal while meeting present requirements. |
| Business establishment | Company or branch, powers of attorney, tax registration and local activity. | Choose the structure around operational and tax requirements. |
| Cross-border financing | Lender, borrower, agreement, use of funds and payment treatment. | Model the current rules and assess any proposed changes as a separate scenario. |
Debt, funds and financing options
InvestChile’s special report also highlights proposals for certain debt instruments, a Junior Segment aimed at innovation and mining exploration, and reforms affecting investment funds. These are separate topics: the treatment of a publicly offered bond cannot simply be applied to a parent-to-subsidiary loan. InvestChile’s summary of the bill.
For planning purposes, we recommend identifying the recipient entity, the documents supporting the investment and the party responsible for local compliance. A useful comparison starts with the actual transaction and viable alternatives. Proposed savings should be shown separately from costs determined under existing rules.
What your business can prepare now
- Investment map: investor, recipient, instrument, currency, term and purpose.
- Corporate records: ownership, representatives and evidence of their authority.
- Scenario analysis: a current-law budget and sensitivity to possible legislative changes.
- Coordination: a joint review by Chilean and home-country advisers so that both sides work from consistent assumptions.
The immediate goal is a structure that supports operations and compliance from the outset. Future legislation may justify a further review; it does not replace the analysis needed for the transaction today.
Frequently asked questions
Has Chile removed the RUT requirement for all foreign investors?
No. The reviewed bill remains under discussion, and the proposed exception covers a specific class of investment. It is not a general removal of tax registration.
Would the proposal remove tax compliance checks when establishing a company?
No. Business establishment requires its own review of the structure, participants and activity. The proposal for certain securities investments does not replace that analysis.
Should a business postpone its investment?
That depends on commercial timing, costs and the transaction. Compare the current-law scenario with realistic alternatives, rather than committing to contracts or budgets that assume proposed benefits are already available.
Official sources and further reading
- Chamber of Deputies: Bill 18,643-05 and legislative status
- Presidential Message 166-374: article four and the proposed amendment to Tax Code Article 66
- Ministry of Finance: reform announcement, 9 September 2026
- SII: RUT registration for a foreign legal entity acquiring Chilean equity interests
- InvestChile: special Legal Report, 16 September 2026
Sources checked on 20 October 2026. Official legislative and administrative sources are in Spanish. Proposed measures may change during the legislative process.
How we can help
At Izquierdo Deramond Consultores we advise on legal and tax structuring, representation and corporate compliance. We can review the planned transaction and map the responsibilities of each participant.