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Borrowing from abroad into Chile: intercompany and bank loans, Central Bank reporting, interest withholding, thin capitalization and stamp tax

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Last verified: 2026-10-26 · Status: Stable

A Chilean company can borrow freely from abroad in any currency, including pesos, at whatever rate it agrees. Loans of US$10,000 or more must come in through a bank or other formal FX market entity and be reported, loans of US$1,000,000 or more also need a report of their financial terms, and every interest and principal payment is reported when it is made. The cost side is tax: 4 percent withholding on interest to foreign banks and qualifying financial institutions or 35 percent otherwise, a 35 percent tax on related party interest over a 3 to 1 debt to equity limit, and stamp tax of up to 0.8 percent of the principal.

USD figures use the Central Bank exchange rate of CLP 986.58 per US dollar published in the Diario Oficial for 23 October 2026 (Ley Nº 18.840 art. 44 and CNCI Chapter I, Section VII). UF values use UF 1 = CLP 41,205.16 (23 October 2026) and UTM values use UTM 1 = CLP 72,151 (October 2026), both as published by the Servicio de Impuestos Internos. Conversions are for orientation only.

Key facts

Foreign loan size that requires a report of its financial terms	1000000 USDCNCI Chapter II, Letter B, Section IV, Nº 20 c), as of 2026-10-26 · in force
Minimum foreign loan subject to channelling and reporting	10000 USDCNCI Chapter II, Letter B, Section IV, Nº 19, as of 2026-10-26 · in force
Non residents may lend to Chilean borrowers in pesos	Yes, through the formal market and reported textCNCI Chapter I, Annex Nº 3, Nº 3 e), as of 2026-10-26 · in force
Withholding on interest to foreign banks and qualifying financial institutions	4 %DL Nº 824 art. 59 Nº 1 b), as of 2026-10-26 · in force
Withholding on interest to other non residents	35 %DL Nº 824 art. 59, as of 2026-10-26 · in force
Debt to equity ratio above which excess indebtedness exists	3 times equityDL Nº 824 art. 41 F Nº 3, as of 2026-10-26 · in force
Stamp tax on credit operations per month	0.066 %DL Nº 3.475 art. 1 Nº 3, as of 2026-10-26 · in force
Stamp tax cap on credit operations	0.8 %DL Nº 3.475 art. 1 Nº 3, as of 2026-10-26 · in force
Maximum reserve requirement the Central Bank may impose on foreign credits	40 %Ley Nº 18.840 art. 49 Nº 2, as of 2026-10-26 · in force

The rule

1. A credit from abroad is any act under which one party delivers or undertakes to deliver foreign currency from abroad to a person domiciled or resident in Chile, who must return it later, with or without interest or adjustment: loans, credit lines, discounting of documents and bank or commercial current account credits and overdrafts. It expressly includes leasing, credit lines and payables to related entities, bonds placed abroad by Chilean issuers (in pesos, UF or foreign currency), loans and buyer advances to finance exports, and credits whose funds are used abroad to pay the debtor's other obligations.FX Compendium (CNCI) approved by Central Bank Agreement Nº 2617-03-240125, in force from 1 January 2026, CNCI Chapter I, Annex Nº 5, Section IV letter c), 2024-01-30 official text · verified 2026-10-26

2. Credits from abroad taken by individuals or companies that are not institutional investors must enter through the formal FX market (unless made with funds abroad) and be reported, if they are US$10,000 or more. Anyone who takes credits from abroad of US$1,000,000 or more must also report the financial terms of each operation to the Central Bank. If the funds are used directly abroad, the Chilean borrower reports that directly to the Central Bank. Each payment of principal, interest or adjustment is reported through the bank when sent from Chile, or directly by the borrower when paid abroad, and later changes (rescheduling, capitalization, assignment) must be reported.
Cost to do it: No Central Bank fee; the cost is the reporting work, usually by the treasury team or an adviser.
Example: An intercompany loan of CLP 986,580,000 needs both the bank inflow report and the financial terms report. / US$1,000,000 triggers the terms report; a US$900,000 loan is reported only as an inflow through the bank.FX Compendium (CNCI) approved by Central Bank Agreement Nº 2617-03-240125, in force from 1 January 2026, CNCI Chapter II, Letter B, Section IV, Nº 18, 19, 20 c), 31 to 35, 2024-01-30 official text · verified 2026-10-26

3. Non residents may grant loans to Chilean borrowers in pesos, and Chilean residents may lend to non residents in pesos, under the Central Bank's authorization for peso operations; those loans must still go through the formal market (unless made from pesos held abroad) and be reported.FX Compendium (CNCI) approved by Central Bank Agreement Nº 2617-03-240125, in force from 1 January 2026, CNCI Chapter I, Annex Nº 3, Nº 3 c) and e), 2024-01-30 official text · verified 2026-10-26

4. Interest paid to persons without domicile or residence in Chile bears 35 percent additional tax, reduced to 4 percent for interest on credits granted from abroad by foreign or international banks or financial institutions (and certain foreign insurers and pension funds), and on foreign currency deposits in institutions authorized by the Central Bank. The 4 percent rate needs a declaration from the lender to the payer that the loan is not part of a structured arrangement passing the interest to someone not entitled to the reduced rate. A foreign financial institution must have lending as its main purpose, earn most of its income from it, lend regularly, and have paid in capital and reserves of at least half the minimum capital required for foreign banks in Chile. The payer must inform the SII of the terms of the operation.
Example: Interest of CLP 69,060,600 a year on a loan from a foreign bank bears CLP 2,762,424 of withholding at 4 percent; from the non bank parent it bears CLP 24,171,210 at 35 percent. / US$70,000 of interest: US$2,800 at 4 percent, or US$24,500 at 35 percent. A tax treaty can lower the 35 percent rate.Decreto Ley Nº 824, Ley sobre Impuesto a la Renta, Art. 59, fourth paragraph, Nº 1 letters a) and b), 1974-12-31 official text · verified 2026-10-26

5. The Chilean payer must withhold additional tax at the applicable rate when it pays, credits or makes interest available to a non resident, and pay it to the Treasury by the 12th of the following month.
Example: Interest paid on 20 November 2026 must have its withholding paid by 12 December 2026.Decreto Ley Nº 824, Ley sobre Impuesto a la Renta, Art. 74 Nº 4 and art. 79, 1974-12-31 official text · verified 2026-10-26

6. Interest and other financial charges paid to related entities abroad that correspond to excess indebtedness bear a 35 percent single tax, declared and paid annually by the Chilean debtor. There is excess indebtedness when the company's total annual debt is more than three times its tax equity at year end. Related entities include group companies, holders of 10 percent or more of capital or profits, financing guaranteed by related parties abroad who are the final beneficiaries of the interest, and back to back arrangements. Credits from unrelated parties of 90 days or less are left out of total debt. The tax base is limited to related party interest that bore the 4 percent rate, a reduced treaty rate, an exemption or no additional tax.
Example: A subsidiary with tax equity of CLP 986,580,000 can carry total debt of up to CLP 2,959,740,000 before the excess rule bites. / Tax equity US$1,000,000, debt ceiling US$3,000,000; see Taxes: thin capitalization for the full calculation.Decreto Ley Nº 824, Ley sobre Impuesto a la Renta, Art. 41 F, 1974-12-31 official text · verified 2026-10-26

7. Documents recording a money credit operation (bills of exchange, promissory notes, simple or documentary credits and any other document, including dematerialized ones) and loans and mutuos of money bear stamp tax of 0.066 percent of the amount per month or fraction between issue and maturity, capped at 0.8 percent; operations payable on demand or with no maturity bear 0.332 percent. For credit operations from abroad with no document, the tax accrues when the loan is recorded in the books in Chile. Renewals and extensions are taxed on the extended capital, with the 0.8 percent cap counting tax already paid if the extension is properly recorded and, for foreign credits, registered or authorized under the FX rules.
Cost to do it: Up to 0.8 percent of principal: US$8,000 (CLP 7,892,640) on a US$1,000,000 loan of 13 months or more.
Example: A 12 month loan of CLP 986,580,000 bears 0.792 percent, CLP 7,813,714. / US$1,000,000 for 12 months: 12 x 0.066 percent = 0.792 percent, US$7,920; for 3 years the cap applies, US$8,000.Decreto Ley Nº 3.475, stamp tax law, Art. 1 Nº 3, art. 2 and art. 14, 1980-09-04 official text · verified 2026-10-26

8. The Central Bank may require credits, deposits or investments in foreign currency coming from or going abroad to keep a reserve requirement (encaje), but only for operations remitted after it is imposed and never above 40 percent of the operation, by a reasoned majority of the full Council, on currency stability or balance of payments grounds and for at most one year (renewable). No such restriction is currently applied.Ley Nº 18.840, Organic Constitutional Law of the Banco Central de Chile; FX Compendium (CNCI) approved by Central Bank Agreement Nº 2617-03-240125, in force from 1 January 2026, Ley Nº 18.840 art. 49 Nº 2 and art. 50; CNCI Chapter I, Sections I and III, 1989-10-10 official text · verified 2026-10-26 · changed: Art. 49 Nº 2 was amended by Ley Nº 21.641 (Diario Oficial 30 December 2023), art. 3 Nº 8.

Item	Foreign bank lender	Related foreign company lender (no treaty)
Stamp tax at signing (cap 0.8 percent)	US$8,000 (CLP 7,892,640)	US$8,000 (CLP 7,892,640)
Interest withholding per year on US$70,000	4 percent: US$2,800 (CLP 2,762,424)	35 percent: US$24,500 (CLP 24,171,210)
Lender declaration needed	Yes, no structured arrangement	No
Central Bank reporting	Bank inflow report plus financial terms report	Bank inflow report plus financial terms report
Thin capitalization test	Counts in total debt; 35 percent single tax applies only to related party interest	Interest on the excess over 3 times equity can bear the 35 percent single tax if it bore less than 35 percent

Tax and reporting cost of a US$1,000,000, 3 year loan into a Chilean company at 7 percent interest (DL Nº 824 art. 59; DL Nº 3.475 art. 1 Nº 3; CNCI Chapter II). CLP at 986.58 per US dollar.

Worked example

A Chilean SpA borrows US$1,000,000 (CLP 986,580,000) for 3 years from a German bank. The funds arrive at its Chilean bank; the SpA declares a credit from abroad, the bank reports the inflow, and the SpA reports the loan's financial terms to the Central Bank because it reaches US$1,000,000 (CNCI Nº 20 c), 31 and 32).
Stamp tax is 0.8 percent because the term exceeds 12 months: US$8,000 (CLP 7,892,640), paid when the loan is recorded in Chile if there is no document (DL Nº 3.475 art. 14).
Interest of US$70,000 a year bears 4 percent withholding, US$2,800 (CLP 2,762,424), once the bank gives the declaration of no structured arrangement; the SpA pays it by the 12th of the month after each interest payment (DL Nº 824 art. 59 and 79), and the bank reports each remittance.
If the same loan came from an Argentine parent instead, interest would bear 35 percent unless the Chile Argentina tax treaty (applied in Chile from 1 January 2017 according to the SII) lowers it, and the debt would count toward the 3 to 1 test of art. 41 F. The Argentine side is covered in the Argentine guide.

Step by step

1. Check the lender type: a foreign bank or qualifying financial institution gets 4 percent; a related company gets 35 percent or the treaty rate.
2. Size the loan against equity: total debt over three times tax equity creates exposure to the art. 41 F single tax on related party interest.
3. Sign the loan agreement and budget stamp tax (0.066 percent per month, capped at 0.8 percent).
4. Receive the funds through a Chilean bank, declare the operation as a credit from abroad and its concept; if the loan is US$1,000,000 or more, report its financial terms to the Central Bank.
5. Before the first interest payment, obtain the lender's declaration (for the 4 percent rate) or treaty residence certificate (for treaty rates).
6. Withhold on every interest payment and pay by the 12th of the following month; the bank reports each remittance.
7. Report any rescheduling, capitalization or assignment of the loan to the Central Bank.

Common traps

Treating an intercompany payable as outside the FX rules. Payables to related entities and leasing are credits from abroad under Annex Nº 5.
Claiming the 4 percent rate for a group finance company. It applies only to foreign banks and financial institutions meeting the art. 59 tests, with a declaration of no structured arrangement.
Forgetting stamp tax on loans with no signed document. For credits from abroad without documents the tax accrues when the loan is booked in Chile.
Capitalizing a loan without a report. A debt to equity conversion is a capital contribution from abroad and a change to a reported credit, both of which must be reported.
Ignoring the 3 to 1 test because the lender is a bank. A bank loan guaranteed by a related party abroad counts as related party financing under art. 41 F Nº 6 when that guarantor is the final beneficiary of the interest.

Sources

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