Opinion | Tax Law – Chile

In a new column published in El Mercurio Legal, Francisco Valdivia and Carlos Salazar analyze the legal presumption of cessation of activities, a concept that is gaining increasing relevance in tax administration and enforcement in Chile.

The article examines the practical effects of this presumption on taxpayers, companies, and tax advisors, highlighting the operational and legal risks that may arise from its automatic application, as well as the tensions it introduces in relation to legal certainty.

The authors also explore the main interpretative challenges posed by this mechanism, including the powers and responsibilities of the Chilean Internal Revenue Service (Servicio de Impuestos Internos – SII) in verifying the circumstances that allow a term of activities to be presumed, along with the unresolved questions surrounding its proper implementation.

This reflection is particularly relevant for those involved in tax planning, tax compliance, and corporate advisory, in a context in which tax authorities are moving toward greater levels of control and automation.

👉 Read the full column in El Mercurio Legal:
https://www.elmercurio.com/Legal/Noticias/Opinion/2026/01/14/915805/presuncion-legal-termino-giro.aspx