On 24 August 2026, the SII reported the completion of 125 transfer pricing audits during the current fiscal period, resulting in tax assessments exceeding 94 billion Chilean pesos (approximately USD 100 million). These examinations targeted multinational enterprises operating in Chile across sectors such as mining, retail, technology, and pharmaceuticals. The audits were conducted under the authority of Article 41 E of the Income Tax Law and the Transfer Pricing Regulations (Resolution No. 110/2020), which align with OECD BEPS Action 13 standards. The SII emphasized the use of advanced data analytics and country-by-country reporting (CbCR) information to select high-risk cases.
Key Takeaways
- Risk-Based Selection Leveraging CbCR: The SII’s audit selection methodology now systematically incorporates CbCR data exchanged under the Multilateral Competent Authority Agreement, enabling identification of entities with low-tax jurisdiction profit allocation inconsistent with economic substance.
- Increased Penalties for Non-Compliance: Beyond primary adjustments, the SII imposed accuracy-related penalties for inadequate contemporaneous documentation, reinforcing the mandatory preparation of local and master files for taxpayers exceeding the 100,000 UF annual revenue threshold.
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