Twenty days after the submission of the National Reconstruction and Economic Recovery Bill, on May 11^th, the Government introduced several amendments (indicaciones) following to meetings with various political sectors. Below, the most relevant highlights in the tax area: 

REDUCTION OF THE FIRST CATEGORY TAX 

Project: Proposes a gradual reduction of the First Category Tax or IDPC (for its initials in Spanish), from 27% to 23% over 4 years (2026 to 2029). While the reduction is presented as applicable to both the General Regime and the Pro-SME Regime, eliminating references to differential rates between both, the Government has publicly committed that the IDPC rate for companies under the Pro-SME Regime would remain at 12.5%. 

Amendment: There is no amendment modifying the permanent rule. The only change in this matter corresponds to the sixth transitory article, where the amendment adds an explicit exclusion: the rates of 27% (2026) and 25.5% (2027) do not apply to taxpayers under letter G) of Article 14 of the LIR, i.e., taxpayers not subject to Article 14. 

REINTEGRATION OF THE TAX SYSTEM 

Project: The obligation to restore the IDPC credit is eliminated. The bill moves toward the full tax reintegration of the system, meaning that 100% of the IDPC paid by the company will be creditable against the final taxes of the partner or shareholder. It removes the distinction between credits with and without a restitution obligation in the SAC register, the Pro-Pyme Regime, and the tax transparency regime. This elimination is implemented gradually, reaching full reintegration by 2030. 

Amendment: None. 

ELIMINATION OF THE 10% SINGLE TAX ON CAPITAL GAINS FROM LISTED SHARES AND FUND UNITS 

Project: Article 107 of the LIR is modified, reinstating the non-taxable income regime for gains obtained from the alienation of securities with stock market presence, thus eliminating the 10% single tax previously contemplated for these operations. 

Amendment: None 

EMPLOYMENT TAX CREDIT AND ELIMINATION OF THE SENCE TAX INCENTIVE 

Project: A credit of 15% is created on individual monthly remunerations paid per worker, applicable to taxpayers under the SME Regime (Article 14 A and D No. 3 of the LIR), for remunerations not exceeding 7.8 UTM. The credit is phased out for remunerations above 12 UTM, with a gradual reduction formula between both brackets. Parallel to this, the SENCE tax incentive for training expenses and the rules regulating courses financed under it are eliminated. 

Amendment: Regarding the job training system, the amendment technically reformulates the rule but maintains the same result: elimination of the incentive and redirection toward formal hiring. 

ELIMINATION OF PROPERTY TAX ON PRIMARY RESIDENCE FOR SENIOR CITIZENS 

Project: A full Property Tax exemption is established, with no cap on assessed value, for individuals aged 65 or older regarding their principal residence. The rule includes a related-party rule preventing its use for properties acquired from related parties within 3 years prior to the filing of the affidavit, unless the taxpayer proves the transfer was due to non-tax reasons. 

Amendment: The amendment replaces the article, expanding the benefit to explicitly include parking spaces and storage units located at the same address as the principal residence (even if they have a different tax ID/role), provided they are intended for residential use. 

• The affidavit must expressly individualize them. 

• A new cause for losing the benefit is added: if the parking spaces or storage units are no longer used for such residential purposes. 

NEW REGIME FOR SMALL DFL 2 RESIDENTIAL PROPERTIES 

Project: The current regime is maintained for the first two “viviendas económicas” (small residential properties), and a 5% single tax is introduced on the gross amount of rental income without any deduction from the third property onward (up to 90 m² per unit). Legal entities and sole proprietorships could voluntarily elect this regime, subject to a minimum 5-year stay and no possibility of re-entry once they decide to exit. 

Amendment: The amendment introduces three relevant changes: 

• The regime under Article 24 bis changes from mandatory to optional for individuals: the phrase “shall be subject” is replaced by “may elect.” 

• Article 24 ter eliminates the minimum 5-year stay for legal entities. Only the prohibition to re-enter remains. Instead, a sole business purpose requirement is added regarding the temporary lease, use, or exploitation under any title of economic housing that meets the requirements: if the taxpayer obtains other income, the regime is permanently lost. 

• Article 24 quáter of the original project, which regulated the REX register and the taxation of withdrawn profits, is eliminated: it was not included in the replacement introduced by the amendments. 

TWENTY-FIVE-YEAR TAX STABILITY REGIME 

Project: For investments exceeding USD 50 million, foreign investors were guaranteed a total effective income tax burden of 35% for 25 years. Local investors, for investments of the same amount, would also be granted 25-year stability regarding the rules in force at the time of the contract, including both income tax and VAT rules. Both foreigners and locals could automatically benefit from subsequent more favorable regulatory changes. In mining, the Mining Royalty under Law No. 21.591 is not considered within the 35% and is added to that burden, though its rules remain stable for the term of the regime. Contracts were signed by the Director of the Foreign Investment Promotion Agency (APEX, for its initials in Spanish). 

Amendment: The amendment introduces relevant institutional and design changes, replacing Article 33 of the Bill: 

• APEX is entirely replaced by the Ministry of Finance as the State counterpart and administrator of the regime (to whom the request is submitted). 

• The fixed 35% rate for foreigners is eliminated and replaced by the effective tax burden applicable under the regulations in force at the date of the contract, generating a dynamic reference instead of a fixed rate. 

• For local investors, the design is simplified by referring to the same rights and terms as foreigners, without reproducing the three explicit rights of the original (IDPC, IGC, and VAT). 

• Mandatory mixed arbitration is added for dispute resolution, which did not exist in the original. 

• The obligation to report business reorganizations to the Ministry of Finance is incorporated. 

VAT EXEMPTION ON THE SALE OF NEW HOMES 

Project: A transitory and optional 12-month exemption for the first sale of homes with final or partial municipal acceptance at the date of publication of the law. The seller retains the right to input VAT credits against other output VAT. Alternatively, they could elect for the remaining credit to form part of the cost of the property or be deducted as an expense. It does not apply to transfers between related companies. For sales already made between the presidential message and the publication of the law, the seller may retroactively apply for the exemption and request a refund of VAT paid, conditioned on proving the tax was returned to the buyer who actually bore it. 

Amendment: The amendment introduces two modifications: 

• Restriction: It eliminates “partial acceptance” as a requirement, requiring only final acceptance (recepción definitiva), reducing the pool of eligible properties. 

• Expansion: The recoverable input VAT credit is extended to goods and services destined for the “construction, development, and/or marketing of the home,” surpassing the original limited scope of construction. 

DONATIONS 

Project: A 50% reduction in donation tax is proposed, exempting them from court-approval (insinuación judicial). The donation must be made via public deed within one year from the first day of the month following the law’s publication. Likewise, the donation must respect the following distribution: at least 50% to legitimaries in their legal proportions; at least 25% to the improvement portion (cuarta de mejoras)  and the remaining 25% freely among the same persons. In no case may the total donated exceed 75% of the donor’s net worth. 

Amendment: The amendments modify the first transitory article, providing more regulation for the application of the benefit: 

• It clarifies that it applies only once per donor regarding potential heirs of legitimaries and the improvement portion, in the proportion freely determined by the donor—eliminating the mandatory proportional distribution formula of the original project. 

• It regulates cases where no legitimaries or heirs of the improvement portion exist at the time of the donation, which must be recorded in the respective affidavit. 

• It reduces the net worth cap from 75% to 50% of the donor’s total assets. 

CAPITAL REPATRIATION 

Project: A rule previously used that allows for the regularization of assets or income located abroad that, having been subject to tax in Chile, were not timely declared. The extraordinary mechanism will apply for 12 months with a 10% single and substitute tax. A reduced rate of 7% will apply if the assets are repatriated within 3 years and certain investment conditions in Chile are met for at least 5 years. 

Amendment: No substantive changes. The third transitory article is substantially identical to the presidential message. The same rates, terms, accreditation requirements, prohibitions for those indicted or convicted, anti-money laundering rules, and liability-extinguishing effects are maintained. However, the possibility of substituting investments located in Chile during the 5-year term is allowed. 

REGULARIZATION OF FUR, STUT, AND EXCESS WITHDRAWALS FROM FUT 

Project: Through a 10% single substitute tax and without right to associated credits, taxpayers may voluntarily regularize, within 8 months, balances of FUR, STUT (capped at the lower of said register and the RAI), and excess withdrawals from FUT pending at the close of commercial year 2025. The payment extinguishes associated credits, releases those amounts from subsequent taxation, and allows withdrawal without following the order of attribution of Article 14 of the LIR. 

Amendment: The amendment expands the benefit, allowing the election to also cover balances as of December 31^st, 2026, in addition to 2025, under the same terms and conditions. This extension is relevant for taxpayers whose balances change significantly during 2026. 

TAX DEBTS (GENERAL TREASURY OF THE REPUBLIC) 

Project: The General Treasury of the Republic (TGR, for its initials in Spanish) may grant payment facilities for 180 days on tax debts overdue until December 31^st, 2025, for individuals, MiPymes, and unclassified taxpayers. Relief of up to 100% of interest and 80% of penalties for lump-sum payments, or up to 95% and 75% respectively in arrangements of up to 24 installments with a 10% down payment. Each taxpayer can access a maximum of 3 arrangements. 

Amendment: None. 

MUNICIPAL DEBTS 

Project: Municipalities may condone 100% of interest and penalties on municipal debts (permits, licenses, and waste fees) accrued within 3 years prior to January 1^st, 2026, and may waive collection actions for debts subject to the statute of limitations. This applies even with ongoing judicial collection, provided there is no final judgment. 

Amendment: None.