⚠️ Nota en desarrollo — última actualización: 3 de agosto de 2026. El Plan de Reconstrucción Nacional (Boletín N° 18.216-05) es un proyecto de ley en tramitación: todavía no es ley y su contenido puede cambiar. Las cifras, tasas y plazos de esta nota son provisionales, sujetos al texto que finalmente se publique. Iremos actualizando esta nota a medida que avance. Nada de lo aquí descrito constituye norma vigente ni asesoría para un caso particular.
Chile is debating the most significant tax reform in years. The Plan de Reconstrucción Nacional y Desarrollo Económico y Social lowers the corporate income tax, re-integrates the income tax system and opens temporary windows to regularise earnings and capital at a reduced rate. Here we explain, in plain terms, where it is going and — above all — how to start preparing.
In 30 seconds: what changes (under the bill)
- The corporate income tax (IDPC) under the general regime falls from 27% to 23% gradually.
- Integration returns: the credit for that tax becomes 100% creditable against the owners (the 35% surrender of the semi-integrated system ends).
- Temporary windows open to regularise accumulated earnings and capital at a reduced rate (around 10%).
- PYME (14 D regime) keep a reduced rate in the short term and gain a new employment credit.
Status of the bill (as of 23-07-2026)
(Source: the Senate's official record of proceedings, boletín 18216-05. This section is updated as the bill advances.)
(Sources on status: the Senate, the Chamber of Deputies and national press. This section is updated as the bill advances.)
The core: a lower rate + re-integration
The IDPC under the general regime (14 A) falls from 27% to 23% gradually, and de-integration ends: the obligation to surrender 35% of the credit is phased out, so that the IDPC becomes 100% creditable again against the owner's final taxes.
IDPC reduction by commercial year (the year that is later filed):
| Commercial year | IDPC, general regime |
|---|---|
| 2026 | 27% |
| 2027 | 25,5% |
| 2028 | 24% |
| 2029 onwards | 23% |
On re-integration: the credit becomes 100% creditable against the owner. The exact pace of that transition (phased in stages or in a single step) and any intermediate percentages are provisional and will be confirmed with the published text.
Pro Pyme regime (14 D): keeps a reduced rate in the short term. Its medium-term path is provisional and will be confirmed with the final text. A new credit for formal employment, creditable against taxes, is also contemplated.
The windows with a deadline (the opportunity in this reform)
Several measures are temporary and are triggered when the law is published, with limited deadlines that reward acting early. (The exact duration of each window will be confirmed with the published text.)
- Substitute tax (around 10%): it would allow historically accumulated earnings to be regularised by paying a single rate, leaving them fully taxed. (Reach over FUR/STUT and the length of the window: to be confirmed.)
- Repatriation of capital: regularise foreign assets and income by paying a reduced rate, with a lower rate if the capital is brought into Chile and the investment is held for a minimum period. (Exact rates and conditions: to be confirmed.)
- Gifts with a reduced rate: it would allow estate planning during one's lifetime by paying a fraction of the gift tax, respecting statutory heirs' shares.
- VAT exemption for new housing: the first sale of new homes exempt from VAT for a limited period; the seller keeps the construction input VAT credit. Relevant for the real estate sector.
- Waiver of interest and penalties on tax and municipal debts, for limited periods.
Why it pays to act early: regularising accumulated earnings at a reduced rate can be considerably more convenient than keeping them subject to the partner's ordinary taxation (which may reach the Global Complementario ceiling). The calculation depends on each taxpayer and on the final text, and the window runs from publication — which is why preparation starts before.
Other measures in the bill
- Capital gains (art. 107 LIR): the bill contemplates removing the single tax on gains from the sale of publicly traded shares and fund units, which would become non-taxable income. (Effective date and scope to be confirmed.)
- Tax invariability: the bill creates a 25-year invariability regime for investments of USD 50 million or more (according to the BCN's parliamentary advisory service). It is the provision most exposed to litigation / Constitutional Court review; the additional rate and the effective date will be confirmed with the published text.
- Property tax: exemption for older adults on their main home, subject to requirements and a sworn statement before the SII; adjustments to the DFL 2 benefit. (Detail to be confirmed.)
- More enforcement: the counterpart to these cuts is an SII with broader powers to cross-check information.
What to do right now
Although the law is not in force, preparation starts now, because the temporary benefits (regularisations, gifts, debt waivers, the employment credit) would carry limited deadlines from publication. We recommend preparing, company by company and partner by partner, an early diagnosis ready to execute as soon as the law is published:
- 14 A companies: model the combined effect of the lower rate and re-integration on your distribution policy; assess the substitute tax if you carry accumulated earnings.
- 14 D PYME: simulate the employment credit against your payroll and clear debts using the waivers.
- Family wealth: assess the reduced rate on gifts and repatriation as part of succession planning.
You can rely on our tax consulting and planning, tax compliance and accounting services. our consulting and tax planning service, tax-compliance and accounting services.
En paralelo a estos cambios, mantén sana tu operación mensual de IVA: revisa los errores de facturación electrónica que te cuestan crédito fiscal antes de presentar el F29.
Frequently asked questions
Is the Plan de Reconstrucción Nacional already law?
No. As of 23-07-2026 the bill is in its final stage: the Joint Committee issued its report (22-07) and the Chamber approved it, but the Senate's vote on that report is still pending. Enactment and publication in the Diario Oficial would follow. There could also be a challenge before the Constitutional Court.
How much does the corporate income tax fall?
The IDPC under the general regime falls from 27% to 23% gradually: 25.5% (commercial year 2027), 24% (2028) and 23% from 2029.
What is "re-integration"?
That the credit for the IDPC becomes 100% creditable against the owner's final taxes, ending the 35% surrender of the semi-integrated system. The exact pace of the transition will be confirmed with the final text.
Does anything change for PYME (14 D)?
They would keep a reduced rate in the short term and would gain a new credit for formal employment, creditable against taxes. The detail will be confirmed with the final text.
What is the substitute tax and how long does it last?
How does this affect you?
What should I do now?
An early diagnosis, company by company and partner by partner, so you can decide in time: the windows would have short deadlines once the law is published.
¿Cómo le afecta a usted?
At C&C we are following this reform closely. Book a 20-minute diagnosis and we will review, with numbers, the possible impact on your company or your family wealth, so your plan is ready as soon as the law is published.
👉 Write to us on WhatsApp (wa.link/s9s7v2) or through the contact section. We will let you know as soon as the bill becomes law.
Claudio Cortés es socio fundador de C&C Contadores Auditores, firma chilena de contabilidad, auditoría y asesoría tributaria. Contador Auditor y Magíster en Tributación de la Universidad de Chile. Análisis del equipo tributario de C&C. About us · LinkedIn
This content is of a general informational nature and does not constitute tax, accounting, labour or legal advice for particular cases. The subject matter is a bill still going through Congress (Boletín N° 18.216-05) and is not law in force; applying it to specific situations requires individual analysis. C&C Contadores Auditores Limitada accepts no responsibility for decisions taken solely on the basis of this content.
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