National Reconstruction Bill: the tax, regulatory, and labor measures that could reshape your company's operations

On April 22, 2026, the Executive introduced to the Chamber of Deputies, under urgent processing, the National Reconstruction and Economic and Social Development Bill (Message No. 018-374). This is not merely a post-disaster reconstruction plan: it is a structural reform with over 40 measures that modifies the corporate tax rate, the tax credit regime, the sectoral permitting system, hiring costs, and public spending rules. If your company operates, invests, or hires in Chile, this bill reshapes several of the rules you work under today.

What changed

The bill is structured around four pillars: physical, economic, institutional, and fiscal reconstruction. Below are the measures with the greatest business impact.

Permanent measures

Corporate tax reduction and full reintegration

• Article 10 amends Article 20 of the Income Tax Law to set the First Category Income Tax (IDPC) at a permanent 23% from tax year 2029. The transition: 27% in 2026, 25.5% in 2027, 24% in 2028.
• The Pro-SME regime converges to the same 23% in 2029. Its differential benefits will focus on tax base determination, not on the rate.
• Article 11 eliminates the obligation to repay 35% of the IDPC credit under the semi-integrated regime, with gradual phase-out: 30% repayment in TY 2028, 20% in TY 2029, full elimination from TY 2030.
• From TY 2030, 100% of the IDPC paid by the company will be creditable against the final taxes of partners or shareholders, regardless of residency.

Elimination of capital gains tax on listed securities

• The 10% flat tax on capital gains from shares and fund units with stock exchange presence (Article 107, Income Tax Law) is repealed, restoring their status as non-taxable income.
• Effective date: January 1, 2027.

25-year tax stability

• Article 33 creates a framework for investments exceeding US$50 million, applicable to mining, industrial, energy, infrastructure, telecommunications, R&D, health, and science projects.
• For foreign investors, the total effective income tax burden is guaranteed at 35% for 25 years.
• Key detail for mining: the Mining Royalty (Law No. 21,591) is not included in the 35% calculation. The actual total burden will be higher; what is guaranteed is the invariability of the Royalty rules in force at the date of the contract.

Formal employment tax credit

• Article 9 introduces a new Article 33 ter to the Income Tax Law: a credit equal to 15% of individual monthly wages not exceeding 7.8 UTM (~CLP 545,000), decreasing to 0% above 12 UTM (~CLP 838,000).
• The calculation base includes social security taxable earnings, plus meal, transportation, and housing allowances paid in cash.
• Cascade application: same-period provisional monthly payments (PPM) → next month's VAT debits → IDPC at year-end → subsequent years' IDPC, with UTM-adjusted carryforward.
• Incompatible with other hiring cost reduction benefits funded from the Budget Law. State-owned enterprises and those with over 50% public ownership are excluded.

Elimination of the SENCE training tax credit

• The IDPC credit for training expenses (Law No. 19,518) is eliminated. The incentive is redirected toward formal hiring.

Regulatory certainty

• The administrative invalidation period for sectoral permits drops from 2 years to 6 months.
• If a project with an Environmental Qualification Resolution (RCA) is judicially annulled, the holder has the right to reimbursement of direct, effective expenses incurred. Exception: if the annulment is based on false information provided by the holder.

Housing and seniors

• 12-month VAT exemption on the sale of new housing with final or partial building approval, including storage units and parking sold together. The exemption does not affect the seller's right to input VAT credit.
• Retroactivity: purchase agreements formalized by public deed from the date the Message was introduced until the law takes effect will also be covered, with the right to a refund of VAT already paid.
• Persons over 65 are exempt from property taxes on their primary residence (new letter F to the Annexed Table of Law No. 17,235), provided the property matches the registered electoral domicile.
• New DFL 2 regime: from the third property onward, rental income will be subject to a flat 5% tax on gross income, with no deductions. Maximum area: 90 m² (previously 140 m²). For legal entities, the regime is optional with notice to the SII, a minimum 5-year permanence, and no possibility of re-entry.

Transitional measures

Capital repatriation

• A voluntary 12-month regime to declare overseas assets and income (acquired before January 1, 2025, or generated through December 31, 2025).
• General rate: 10%. Reduced rate: 7% if assets are brought into the country within 3 years and remain invested in Chile for at least 5 years.
• Capital from FATF high-risk jurisdictions is prohibited.
• Failure to use the regime operates as a criminal aggravating factor for future tax offenses related to assets that could have been declared.

Substitute tax on accumulated earnings

• 10% rate on positive balances of FUR, STUT, and excess withdrawals from FUT. Deadline to exercise the option: 8 months from the law's publication.
• Payment is made without the right to the associated IDPC credit.

Donation tax reduction

• 50% reduction of the donation tax (Law No. 16,271) for donations formalized by public deed within one year. The judicial approval (insinuación) requirement is eliminated.
• Mandatory distribution: at least 50% to forced heirs (legitimarios), 25% to improvement share beneficiaries (Article 1195, Civil Code), and the remaining 25% only to those same beneficiaries. Cap: no more than 75% of total net worth may be donated.
• The donee may finance the tax with loans from the donated companies, without triggering Article 21 Income Tax Law taxation.

Tax debt forgiveness

• The Treasury is authorized to grant payment facilities for taxes owed through December 31, 2025, within 180 days of the law's publication.
• Full payment: forgiveness of up to 100% of interest and 80% of penalties. Payment plan: up to 95% of interest and 75% of penalties, with a minimum 10% down payment and a maximum of 24 installments.

What this could mean for your company

The IDPC reduction to 23% and full reintegration are the most significant measures. If your company is under the semi-integrated regime, the combination of both reduces the effective tax burden on distributed earnings. But the timeline is gradual: the rate drops only from tax year 2027, and the full elimination of the repayment obligation is completed in TY 2030. There is no immediate benefit in 2026 for general regime taxpayers.

The formal employment tax credit (Article 33 ter) changes the hiring equation for companies with payrolls concentrated in the CLP 545,000 to CLP 838,000 gross monthly range. The Government estimates an annual injection of US$1.4 billion and a reach of over 4 million workers.

The elimination of capital gains tax on listed securities (Article 107) reverses the regime introduced by Law No. 21,420. If you hold positions in Chilean listed stocks, the timing of disposal gains tax relevance from January 1, 2027.

The transitional VAT exemption on new housing targets an estimated stock of 100,000 unsold units. The retroactivity of the measure (from the date the Message was introduced) is an operational detail for developers with deeds already in process.

The capital repatriation at 10% (or 7% with reinvestment) has a double edge: the rate window is generous, but non-compliance creates a concrete criminal aggravating factor for future tax offenses tied to those same assets.

A cross-cutting gray area: the bill is under urgent legislative processing but is not yet law. Its content may be amended during congressional debate.

What you can do

1. Review your 2026-2030 tax planning in light of the full timeline: IDPC reduction (27% → 25.5% → 24% → 23%), gradual repayment elimination (30% in TY 2028, 20% in TY 2029, 0% from TY 2030), and the salary-versus-dividend restructuring that full integration enables.
2. Assess whether your payroll qualifies for the formal employment tax credit (Article 33 ter). Identify how many workers have gross wages between 7.8 and 12 UTM, estimate the potential monthly credit, and model the cascade application (PPM → VAT → IDPC) based on your tax debit and credit profile.
3. If you have undeclared overseas assets or income, or positive balances in FUR, STUT, or excess FUT withdrawal records, begin preparing documentation for the repatriation regime (10%/7%, 12-month window) and the substitute tax (10%, 8-month window) before the law is published.

If you need to evaluate how this bill impacts your tax structure, hiring policy, or sectoral permits, schedule a consultation with our team.

This content is for informational purposes only and does not constitute legal advice for any specific case. The bill is under legislative processing and its content may be amended during congressional debate.