TAX
REFORM

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CORPORATE TAXATION

  • The Bill proposes a gradual reduction of the Corporate Income Tax rate, currently set at 27% to 23% for medium and large enterprises.
  • This reduction would be implemented progressively during the government’s term, as follows:
    • 27% for income accrued or received during the 2026 commercial year;
    • 25.5% for income accrued or received during the 2027 commercial year;
    • 24% for income accrued or received during the 2028 commercial year; and
    • 23% for income accrued or received during the 2029 commercial year.
  • Accordingly, the monthly provisional tax payments for the months of January through March will be adjusted during the transition period as follows:
    • January – March 2027: reduced by 5.56%.
    • January – March 2028: reduced by 5.88%.
    • January – March 2029: reduced by 4.17%.

  • The proposal contemplates the introduction of a fully integrated tax system, replacing the current semi-integrated regime that presently applies to the general income tax system.  
  • Consequently, the Corporate Income Tax paid at the company level would be fully creditable -100% instead of the current 65%- against the final taxes applicable to its owners (Personal Income Tax or Withholding Tax).
  • For these purposes, the current obligation to repay 35% of the credit is eliminated.
  • The application of this measure will be gradual, achieving full reintegration by the year 2030. In this manner, the obligation to repay corporate income tax credits will decrease gradually as follows: 30% for credits generated during the 2028 tax year and 20% for credits generated during the 2029 tax year, eliminating said obligation for the year 2030.
  • This measure aims to simplify the structure of the tax system and strengthen investment incentives by eliminating the need to distinguish between domestic and foreign investors, as well as between investors resident in jurisdictions with double taxation treaties and those resident in jurisdictions without such treaties.

  • The Bill proposes the creation of a tax credit applicable to the monthly wages paid to each employee, equivalent to 15% for wages up to 7.8 UTM (approx. USD $560,000), which decreases progressively until reaching 0% for wages above 12 UTM (approx. USD $847,000).
  • The credit percentage is determined by applying a rate to each employee’s monthly earnings, with earnings defined as taxable income and cash allowances for food, transportation, and housing.
  • This credit may first be applied against Monthly Provisional Payments and, if any balance remains, against VAT and, finally, against Corporate Income Tax. If any remains, it may be used in periods following the one in which it was generated.
  • This benefit will apply to both companies subject to the general tax regime and SMEs.
  • This measure provides a direct incentive for formalizing employment, allowing companies to deduct from their Monthly Provisional Payments, VAT, or Corporate Income Tax, as applicable, a percentage of the costs associated with hiring workers in sectors characterized by high vulnerability or informality.

Effective date: first day of the month following the law’s publication. 


The information contained in this publication was prepared by Carey y Cía. Ltda. for educational and informational purposes only and does not constitute legal advice.