On 31 August 2026, Chile’s Internal Revenue Service (SII) issued Circular No. 35, significantly updating the procedural framework for administrative tax disputes. The circular revises instructions for the Voluntary Administrative Appeal (RAV), the Mandatory Administrative Appeal (RAF), and the Hierarchical Appeal, aligning them with recent amendments to the Tax Code. It expressly repeals Circular No. 34 of 27 June 2018, Circular No. 26 of 18 June 2026, and Chapter IV of Circular No. 12 of 2021, consolidating current appeal procedures into a single authoritative instrument. The update responds to Law No. 21.713 modifications to Article 124 of the Tax Code, ensuring taxpayers and practitioners follow the latest statutory timelines, formatting requirements, and evidentiary standards when contesting tax assessments.
Key Takeaways
- Consolidated Appeal Procedures: The circular merges RAV, RAF, and hierarchical appeal rules into one document, eliminating conflicting guidance from prior circulars and providing a unified reference for taxpayers and tax advisors.
- Alignment with Law 21.713: Procedural deadlines, submission formats, and documentary evidence requirements now reflect the 2026 Tax Code amendments, reducing the risk of procedural dismissals due to outdated practices.
- Immediate Effect and Compliance: Effective from publication date, all pending and new administrative challenges must comply with the updated instructions; taxpayers should review existing appeal strategies to ensure conformity.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement