Chile · Administrative guidance
Chile sets remission criteria for settling tax disputes
On 23 October 2026, Chile’s Internal Revenue Service issued Resolution 145 setting interest and penalty remission criteria for conciliation and out-of-court tax settlements under Tax Code articles 132 bis and 132 ter.
- Official document:
- Resolución Exenta SII N°145 (23October2026), operative1–6; Resolución Exenta SII N°106/2022, operative1(E); Decreto437/2025, Article7(a)–(c)
- Development date:
- 2026-10-23
The resolution provides maximum remission of 80% for late-payment interest and 80% for fines. It provides an additional 5% where the taxpayer agrees to pay the entire adjusted tax debt in one instalment within the month following the tribunal’s authorisation of the out-of-court settlement. Full remission may be proposed only where evidence shows that the relevant charges arose for reasons not attributable to the taxpayer.[1]
The resolution excludes the specified tax-offence evidence-gathering process, tax-crime proceedings and unsatisfied criminal-penalty cases, as well as convictions for bribing tax, customs or Treasury officials. It applies to conciliations conducted and settlements concluded during the year starting with publication of its extract in the Official Gazette. That publication date has not been verified, so this article does not establish that the new criteria are already operative.[1]
The instrument removes operative 1(E) of Resolution 106 of 17 November 2022, which referred remission proposals to the policy applicable when the agreement was reached. The new criteria address settlement of existing tax litigation, rather than an automatic general waiver of tax debts.[1][2]
Article 7(a)–(c) of Decree 437 of 30 April 2025 retains precedence for its exceptional cases. These cover specified evidenced financial difficulties, applications involving net tax debt above 2,500 UTM and other substantiated exceptional circumstances, with Treasury and SII involvement as prescribed. A group tax team should establish the applicable route and supporting evidence before relying on the headline percentages.[1][3]
Official sources
- [1] Resolución Exenta SII N°145
Servicio de Impuestos Internos · Document date: 2026-10-23
Original3pages/131lines read by worker and parent: operative1 principles and Decree7 priority72–85; operative2 remission86–100; exclusions101–114; amendedbase118–119; relativecommencement120–124. Parent does not infer verified Gazette date.
- [2] Resolución Exenta SII N°106
Servicio de Impuestos Internos · Document date: 2022-11-17
Historicaloriginal5pageResolution106/2022. Worker entire314-line extraction; parent195-line extraction read in two windows. Amendedoperative1(E)178–186; priorpolicyreference, not current2026 consolidatedCode certification.
- [3] Decreto437, política de condonaciones
Ministerio de Hacienda / official BCN text · Document date: 2025-04-30
OfficialBCN Decree437, issued30April2025/published18June2026. Article7(a)–(c)40–58 and evidentiaryrequirement61 read. No generaltable/currentCode computation claimed.