Reconstruction and economic development bill
The Executive announced the introduction of a bill that includes more than 40 measures aimed at reactivating the economy, strengthening employment and adjusting the tax system.
From a technical perspective, the proposal is based on five lines of action:
– Tax competitiveness
– Promotion of formal employment
– Simplification of regulations
– Legal certainty for investment
– Containment of public spending
The design combines structural modifications (corporate tax and integration) with transitory economic incentive measures.
Structural modifications to the general regime
Gradual reduction of the IDPC rate
A reduction from the current 27% to a target rate of 23% is announced. The schedule was not disclosed in the public announcement, but the Executive’s technical minute establishes that the rate remains at 27% during 2026, drops to 25.5% in 2027, to 24% in 2028, and reaches 23% in 2029.
Progressive reintegration of the system
The reestablishment of the full imputation of the IDPC against the final taxes of the owners is announced, eliminating the restitution obligation in force under the semi-integrated regime. The full reintegration of the system would not be completed until the 2031 tax period.
Tax invariability regime
Reintroduction of a legal-tax stability mechanism for long-term investments, for a period of 25 years, similar to the repealed DL 600.
Substitute tax on credits with restitution obligation
For credits currently subject to restitution, a substitute tax rate of 15% is contemplated to replace the current 35%, with the effect of converting them into credits without restitution obligation.
SME Regime
The transitory reduction regime established in Law No. 21,755 is maintained, with rates of 12.5% for 2026 and 2027, and 15% for 2028, subject to compliance with specific requirements.
Transitional measures for collection and special regimes
Repatriation of capital
General regime (rate 10%) Extraordinary, voluntary and temporary system of declaration of assets and income located abroad, subject to a single and substitute tax of 10%, effective for 12 months from the publication of the law.
Reduced rate (7%) with conditions
The 7% rate is subject to two simultaneous requirements: effective repatriation within the first three years from the publication of the law, and maintenance of the investment in specific instruments – DFL2 real estate or securities of article 107 of the LIR – for a minimum of eight years. Early withdrawal requires the payment of the difference, reaching a rate of 10%.
Donation tax
Transitory reduction (Law No. 16,271) Reduction of the tax at 50% of the current rate for 12 months from the effective date of the law. The credit imputable to the inheritance tax for the total amount of the tax determined is maintained. The judicial insinuation procedure is eliminated, replacing it by a sworn statement before the SII.
Tax credit for formal employment
Credit equivalent to 15% of gross remuneration for workers with remuneration between 7.8 UTM (~$545,000) and 12 UTM (~$838,000 monthly), with progressive reduction to 0% when exceeding the upper bracket. The credit is imputable against PPM, VAT and IDPC.
Real Estate Taxation
Transitional VAT exemption – sale of new homes
Optional VAT exemption for 12 months, applicable to homes with partial or definitive municipal reception at the time of publication of the law. The measure applies exclusively to the stock already built at that date. Includes warehouses and parking lots sold jointly, promises of sale entered into in the same period and sales entered into since the entry of the presidential message.
Exemption from property tax
Exemption from property tax on the main residence of persons over 65 years of age, limited to one property per taxpayer to one property per taxpayer nationwide, with a compensation mechanism to the Municipal Common Fund.
Environmental Regulation
Reduction of invalidation terms
The term for administrative invalidation of sectorial permits is reduced from 2 years to 6 months. Precautionary measures that can paralyze already approved projects are limited to 6 months. The SEA receives powers to filter sectorial agencies.
Reimbursement for judicially annulled RCA
Mechanism for reimbursement of expenses incurred by project holders with approved RCAs that are subsequently annulled in court.
What does this mean in practice?
– The measures are aimed at reactivating investment and liquidity in the short term
– Opportunities are opened up in tax planning (donations, repatriation, real estate)
– Relevant changes in the structure of the system (rate and integration)
Recommendation:
Evaluate in advance the impact on current structures and possible tax optimization opportunities.
Attention:
The information contained in this presentation is based on public information in the media and announcements made by the Executive, which are preliminary in nature. To date, the final text of the bill has not been submitted to the National Congress. Consequently, the content, scope, conditions of application and effects of the described measures could be modified during the legislative process.
