Court allows deduction of Chilean dividends for tax comparison despite lack of tax treaty.

The Supreme Administrative Court allowed the deduction of Chilean dividends when comparing Finland's and Chile's tax levels, despite the absence of a tax treaty between the two nations. The taxpayer argued that these dividends constituted taxable income under the Law on Taxation of Shareholders of Foreign Intermediary Companies, while the opposing party contended that the lack of a treaty precluded such treatment. The court ruled in favor of the taxpayer, establishing that the statutory definition of taxable income for foreign intermediaries takes precedence over the absence of a specific tax agreement.