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The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Chilean tax treaties
Introduction
Chile has twenty-four tax treaties currently in force and another three treaties
already concluded awaiting parliamentary ratification. Furthermore, it is now
negotiating several tax treaties.
Chile's experience as a tax treaty partner is relatively recent. Its first tax
treaty was signed with Argentina in 1976 and entered into force in 1986. This
treaty follows the Andean Pact Model (1971). As of 1999, Chile became more
active in negotiating and concluding tax treaties mainly based on the OECD Model
Tax Convention on Income and on Capital (OECD Model) and the United Nations
Model Double Taxation Convention between Developed and Developing Countries (UN
Model) with some differences derived from Chile's particular tax system.
The policy that Chile has followed in its tax treaty negotiations after signing
its treaty with Argentina has been very consistent. Such policy has not been
modified by the recent accession of Chile to the OECD, with the exception of the
introduction of the new standard on the exchange of information which has been
agreed in the recent treaties signed with Australia and the USA.
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