SII confirma que donación en el extranjero de acciones extranjeras con activos subyacentes chilenos no tributa en Chile
Jurisdiction | Chile |
Law Firm | Garnham Abogados |
Published date | 15 November 2021 |
El 3 de noviembre de 2021, el Servicio de Impuestos Internos publicó el Oficio Nº 3110, en el cual confirma la ausencia de aplicación de impuestos en Chile a una donación de acciones extranjeras con activos subyacentes chilenos, recibida por una sociedad panameña de propiedad de un contribuyente domiciliado en Chile.
La consulta plantea el caso en que una fundación panameña (Fundación) planea donar en Panamá el 100% de las acciones de una sociedad panameña (PanCo Uno), a otra sociedad panameña (PanCo Dos). Se consulta si esta operación debe tributar con impuestos a la renta o con el impuesto a las donaciones en Chile.
En principio, la respuesta parece evidente, ya que se trata de una operación realizada en el extranjero, entre extranjeros y respecto de activos extranjeros, por lo que no debiera tributar en Chile. Sin embargo, la consulta detalla que PanCo Uno es dueña de activos situados en Chile, y que el dueño de la donataria (PanCo Dos) es una persona natural domiciliada y residente en Chile.
A este respecto, el SII razona que, por tratarse de una donación, el enajenante no genera renta alguna, por lo que no es posible aplicar la...
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