• Companies that, at the end of the 2025 or 2026 commercial year, as applicable, have a positive balance in the Fondo de Utilidades Reinvertidas (“FUR”) and/or in the Saldo de Utilidades Tributables (“STUT”) may elect to apply a 10% sole substitute tax in lieu of final taxes on all or part of such balance.
• The taxpayer will not be entitled to use the Corporate Income Tax credits associated with the amounts subject to the regime, which will be deemed extinguished for all legal purposes.
• This option may be exercised within 8 months from the publication of the law, that is, until June 17, 2027, with respect to the balances determined as of December 31, 2025 or 2026, as applicable.
• The option will be deemed exercised upon the simultaneous filing and payment of the tax, through a form to be established by the Chilean IRS by resolution.
• The amounts subject to the tax may be withdrawn, remitted or distributed without being subject to the allocation order established under the Income Tax Law.
• To determine the balance eligible for the substitute tax, the balance of the respective register (FUR or STUT) as of December 31, 2025 or 2026, as applicable, corresponding to income subject to final taxes will be considered, net of the allocations to be made to such register during the 2026 or 2027 tax year, duly adjusted for CPI variation.
  
  In the specific case of the STUT, the tax will apply to the lower of the balance of such register and the balances recorded on the same date in the RAI register, both net of the amounts of the fiscal year’s transactions to be allocated to such registers.
• The amounts subject to the substitute tax must be deducted from the corresponding register (FUR or STUT). Likewise, the corresponding Corporate Income Tax credit must be deducted from the associated credit control, which amount will be deemed extinguished.
• In the case of the FUR, taxpayers electing to pay the substitute tax will not be subject to Transitory Article 16 of Law No. 21,210. Likewise, the amounts of the FUR balance must be deducted from the tax basis of equity interests acquired through reinvestments of profits made as from January 1, 2015, and from paid-in shares of a corporation acquired through reinvestments of profits, regardless of their acquisition date.
• The tax paid, as well as the expenses incurred, may not be deducted as an expense.

Effective date: the option may be exercised between October 17, 2026 and June 17, 2027.

• Companies that, at the end of the 2025 or 2026 commercial year, record excess withdrawals from the Taxable Profits Fund (“FUT”) may elect to apply a 10% sole substitute tax in lieu of final taxes on all or part of the balance, without the right to the credits contained in the SAC register.
• The option may be exercised within 8 months from the publication of the law, through the simultaneous filing and payment of the tax using the form to be established by the Chilean IRS.
• To determine the balance of excess withdrawals eligible for the regime, the amount of excess withdrawals as of December 31, 2025 or 2026 must be considered, less the allocations to be made to the corporate income registers during the corresponding 2026 or 2027 tax year, duly adjusted for CPI variation.
• The amounts subject to the substitute tax must be deducted from the excess withdrawals register kept by the taxpayer.
• If applicable, the Corporate Income Tax credit to which the taxpayer would have been entitled had the option not been exercised must be deducted from the SAC recorded as of December 31, 2025 or 2026, which amounts will be deemed extinguished for all legal purposes.
• This tax, as well as the expenses incurred for its application, may not be deducted as an expense.

Effective date: the option may be exercised between October 17, 2026 and June 17, 2027.