Exhibit 8.2
[Barros y Errázuriz Abogados letterhead]
January 10, 2013
CorpBanca
Rosario Norte 660
Las Condes
Santiago, Chile
Ladies and Gentlemen,
As Chilean tax counsel to CorpBanca, asociedad anónima organized under the laws of the Republic of Chile (the “Bank”) in connection with the preparation and filing of the preliminary prospectus supplement relating to the issuance and sale by the Bank of US$800 million aggregate principal amount of 3.125% senior notes due 2018 (the “Notes”) dated January 3, 2013 with the Securities and Exchange Commission (the “Commission”) together with the base prospectus supplement dated April 14, 2011 (the “Base Prospectus” and collectively, the “Preliminary Prospectus”), and the final prospectus supplement relating to the Notes dated January 11, 2013 together with the Base Prospectus (the “Final Prospectus” and together with the Preliminary Prospectus, the “Prospectus”), we hereby confirm to you that the discussion set forth under the heading “Tax Considerations— Chilean Tax Considerations” in the Prospectus is accurate in all material respects.
We are lawyers admitted to practice in the Republic of Chile and the aforementioned opinions are limited to the laws of the Republic of Chile as in effect on the date hereof.
We hereby consent to the filing of this opinion as an exhibit to the Current Report to be incorporated by reference in the Bank’s Registration Statement on Form F-3 (File No. 333-173509) as Exhibit 8.2 thereto. In giving such consent we do not thereby admit that we come within the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission promulgated thereunder.
Sincerely, |
/s/ Barros y Errázuriz Abogados |
Barros y Errázuriz Abogados |