On 27 October 2026, the SII and the Chilean Institute of Tax Law (ICHDT) held a technical forum focused on transfer pricing risks faced by multinational corporations in Chile. The event addressed recent audit trends, documentation requirements, and the application of the arm’s length principle in the digital economy. Participants discussed practical challenges in benchmarking and the use of bilateral advance pricing agreements (APAs) to mitigate double taxation risks.
Key Takeaways
- Focus on Digital Economy: The forum highlighted emerging risks in digital business models, urging taxpayers to strengthen documentation for intangible-heavy transactions.
- APA Promotion: The SII encouraged the use of bilateral APAs with treaty partners to provide certainty and reduce audit exposure for complex intercompany arrangements.
- Documentation Best Practices: Experts recommended adopting a master file and local file approach consistent with OECD BEPS Action 13, ensuring readiness for SII information requests.
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