1. Reduction of the First Category Tax (Corporate Income Tax)

 

The bill reduces the First Category Tax (Impuesto de Primera Categoría – IDPC) rate from the current 27% to 23% for taxpayers subject to the general regime under Article 14(A) of the Income Tax Law (LIR). The reduction is gradual and set out in Article 6 of the transitional provisions, following this schedule:

• FY 2026: 27%

• FY 2027: 25.5%

• FY 2028: 24%

• FY 2029 onward: 23% (permanent rate)

 

The Pro Pyme regime (Article 14(D)(3)) maintains the transitional rates established under Law No. 21,755 for FY 2027 and 2028, likewise converging to 23% from FY 2029 onward, thereby eliminating the current rate differential between regimes.

 

2. Reintegration of the tax system

​

The obligation to restitute part of the corporate tax credit under the current semi-integrated system would be eliminated, transitioning back to a fully integrated system, under which 100% of the IDPC paid at the corporate level would be creditable against shareholders’ final taxes (Personal Income Tax or WHT).

​

The transition is gradual and established in Article 5 of the transitional provisions:

• FY 2026 (current regime): 35% restitution (65% credit available)

• FY 2027: 30% restitution (70% credit available)

• FY 2028: 20% restitution (80% credit available)

• FY 2029 onward: no restitution (100% credit available)

 

During the transition period, withdrawals must be credited in strict chronological order: first against balances accumulated in the SAC (Corporate Tax Credit Register) as of FY 2026 year-end under the rules then in force, and subsequently against annual balances generated under the progressively reduced restitution percentages.

​

For foreign shareholders protected under double taxation treaties, who already had access to the full 100% credit, the reform produces no material change. The principal impact falls on non-treaty investors, who currently may credit only 65%, and whose effective maximum tax burden would decrease to approximately 35% under full integration.

​

3. Tax credit for formal employment (new Article 33 ter LIR)

Effective date: First day of the month following publication in the Official Gazette.

 

A new Article 33 ter is introduced into the LIR establishing a tax credit against IDPC available to taxpayers under both:

• the general regime (Article 14(A)), and

• the Pro Pyme regime (Article 14(D)(3)).

 

The credit is calculated based on each employee’s monthly compensation, including taxable remuneration plus cash-paid allowances for meals, transportation, and accommodation. It is prorated for part-time employment.

 

Credit rates:

• 15% for remuneration up to 7.8 monthly UTM

• Gradually reduced for remuneration between 7.8 and 12 UTM

• 0% for remuneration equal to or exceeding 12 UTM

 

The credit is first offset against monthly provisional tax payments (PPM). Any excess may be applied against VAT debits in the following month or carried forward to future tax years until fully used. The credit does not generate refunds. Restrictions:

• State-owned companies or entities with more than 50% public ownership are excluded

• The credit cannot be combined with other public hiring-cost subsidies applicable to the same employee

• Fraudulent use results in loss of the benefit and criminal sanctions

 

As a related measure, the SENCE training tax credit (Articles 26 and 27 permanent provisions) — which allowed taxpayers to offset up to 1% of taxable payroll against IDPC — is repealed.

​

4. Elimination of tax on publicly traded capital gains

Effective date: 1 January 2027 (deferred effectiveness under Article 9 of the transitional provisions).

​

Article 107 LIR is amended to restore the status of non-taxable income (ingreso no constitutivo de renta) to capital gains derived from the disposal of:

• publicly traded shares, and

• publicly traded mutual fund and investment fund units.

 

This reverses the 2022 reform, which introduced a 10% flat tax on such gains. Consequently, the following are also repealed:

• stock-market loss deduction rules

• withholding mechanisms

• related reporting obligations

 

5. Property tax exemption for senior citizens

Effective date: 1 January of the year following publication in the Official Gazette.

 

A 100% exemption from municipal property tax (impuesto territorial) is introduced for individuals aged 65 or older, with respect to their principal residence, defined as their habitual residence whose address matches their electoral address registered with SERVEL.

 

Conditions and limitations:

• Limited to one property nationwide

• Applies to mixed-use properties if residential surface represents at least 50% of total built area

• In cases of co-ownership:

  • all co-owners must be individuals, and

  • the resident must hold at least 50% ownership, or 25% if acquired through succession from a deceased spouse or civil partner

• Requires filing a sworn statement with the SII

 

Audit and penalties:

The SII may cross-check information with the Civil Registry, SERVEL, and the Investigative Police (PDI) to verify effective residence. Improper claims trigger severe penalties:

• fine equal to 300% of the avoided tax

• 10-year disqualification from accessing the benefit

 

Surviving spouses or civil partners may retain the benefit for up to three years following the owner’s death.

 

An anti-avoidance rule prevents artificial transfers among relatives or related entities.

 

6. New DFL-2 rental regime: 5% flat tax

Effective date: 1 January 2027 (deferred effectiveness under Article 9 transitional provisions).

​

DFL-2 is amended to introduce a simplified taxation regime on rental income derived from small residential units (maximum 90 m² per unit) through new Articles 24 bis, 24 ter and 24 quáter.

​

Individuals (Article 24 bis)

Rental income becomes subject to a 5% flat income tax, applied on gross contractual rent without deductions, beginning with the third qualifying property onward. The first two qualifying units remain subject to the current DFL-2 regime.

​

Legal entities and sole proprietorships (Article 24 ter)

Legal entities and individual businesses (from the third qualifying property onward) may elect the same 5% flat tax on gross rental income for all qualifying units.

 

The election must be notified to the SII:

• upon commencement of activities, or

• within the deadline established by administrative resolution

 

If exercised later, it applies starting the following tax year. The election is:

• irrevocable for at least five consecutive tax years

• unavailable again once abandoned

 

Effects of the regime (Article 24 quáter)

Payment of the tax fully satisfies income tax liability. Amounts are recorded as fully taxed income in the REX register and may be withdrawn, remitted or distributed under the rules of Article 14(A)(4) LIR.

 

Taxpayers must still:

• make monthly provisional payments (5% / 12)

• file an annual tax return under Article 65 LIR

 

7. Tax stability regime for large investments

Effective date: First day of the month following publication. Stability applies from execution of the agreement with the State and lasts 25 years.

 

Article 33 introduces a 25-year tax stability regime for projects involving investments of USD 50 million or more, including projects in:

• mining

• industry

• forestry

• energy

• infrastructure

• telecommunications

• R&D

• medical and scientific sectors, among others.

 

The regime is formalised through contracts entered into with the Chilean State.

 

For foreign investors

• Maximum effective income tax burden capped at 35% (excluding mining royalty)

• Stability of the essential elements of the tax regime in force at the time of contract execution

• Freezing of VAT treatment and customs tariff treatment for imported capital goods during project execution

• Mining projects receive additional stability regarding:

  • mining royalty

  • new mining-specific taxes

  • adverse changes to exploration and exploitation concession fees

 

For domestic investors

• Same investment thresholds and duration

• Stability granted with respect to:

  • IDPC

  • Personal tax

  • VAT

​

Additional stabilised matters (both investor categories): Administrative interpretations issued by the SII relating to: depreciation, tax loss carryforwards, start-up and initial expenses.

 

The regime may extend to projects forming part of a single operating unit or designed to:

• maximise performance

• incorporate updated technologies

• expand productive capacity

• increase efficiency levels

 

If subsequent legal or administrative changes become more favourable, investors may apply them in lieu of the agreed stability regime.

​

8. SII data interoperability powers

Effective date: First day of the month following publication.

 

Article 59 of the Tax Code is amended to clarify the authority of the SII to request, receive, and cross-check information from any database or registry maintained by public administration bodies, where necessary for tax enforcement.

​

The SII is expressly required to ensure confidentiality and data protection under existing secrecy rules.

​

A new Article 85 quáter of the Tax Code also requires the Ministry of Social Development and Family to provide the SII with access to data contained in the Social Household Registry (RSH), exclusively to enable more accurate auditing and proper application of tax benefits and liabilities.