Executive Summary
Chile’s tax agenda in early November 2026 is dominated by Law No. 21.850 ‘s’reconstruction measures and implementing circulars, the new Single Substitute Tax on accumulated untaxed income under Law No. 21.780, and an expanded cooperative compliance program featuring Advance Pricing Agreements. Parallel modernization of electronic tax documents and targeted enforcement campaigns on trusts and foreign accounts round out the period.
Important Updates
Law No. 21.780 — Single Substitute Tax (IUS) on Accumulated Untaxed Income (RAPT)
Law No. 21.780, published in the Official Gazette on October 18, 2026 and in force on October 21, 2026, establishes the Single Substitute Tax (Impuesto Único Sustitutivo – IUS) on accumulated untaxed income (rentas acumuladas pendientes de tributación – RAPT). The statute reforms the corporate tax integration system by allowing companies to elect a 15% substitute tax on RAPT balances as of December 31, 2025, replacing the previous regime under which retained earnings were subject to the 35% corporate rate plus additional tax upon distribution. The election is voluntary, irrevocable, and payable in two installments.
The election must be made via Form 22 for tax year 2026 by November 30, 2026, with the first installment due the same date and the second by April 30, 2027. Once paid, RAPT is considered taxed and future distributions are exempt from additional tax. Anti-avoidance rules prevent artificial inflation of RAPT. The measure applies to roughly 45,000 Chilean corporations, including family-owned businesses, real estate companies, and multinational subsidiary structures, and is designed to unlock CLP 8 trillion in retained earnings. SII Resolution Exenta No. 147 (October 20, 2026) supplies operational details.
Sources: SII News: New Single Substitute Tax for Accumulated Untaxed Income Enters into Force
Law No. 21.850 — Reconstruction and Economic Development Law and Implementing Measures
Law No. 21.850 (National Reconstruction and Economic and Social Development Law) was published in the Official Gazette on October 19, 2026. The omnibus law introduces a temporary 2% surcharge on First Category corporate income tax for companies with annual taxable income above CLP 100 billion for tax years 2026 and 2027, a VAT exemption for construction materials used in social housing reconstruction, two-year accelerated depreciation for machinery and equipment in affected zones, an increased donation tax credit of 50% (capped at 5% of taxable income), a two-year property tax exemption for destroyed primary residences, and a 0.1% employer payroll levy to fund a monthly pension bonus for the elderly.
The SII has issued implementing instruments for the law. Exempt Resolution No. 146 (October 23, 2026) creates a special VAT refund procedure under the fourth transitional article of Law 21.850, while Exempt Resolution No. 141 (October 19, 2026) establishes the form for declaring and paying the Unique Substitute Tax on Reinvested Profits Fund balances and excess withdrawals under transitional articles 11 and 12. A separate special procedure for VAT refunds on housing sales (Resolution Exenta No. 145, October 30, 2026) uses Form 3250 and shortens refund processing to 30 business days. Additionally, the SII released seven circulars for public consultation from November 5 to November 25, 2026 covering accelerated depreciation, VAT refund mechanisms, temporary income tax credits, SME compliance simplifications, loss carryforwards, modified transfer pricing thresholds, and anti-abuse provisions, including a 50% additional deduction for new hiring in affected communes for 24 months.
Approximately 300 large corporations must compute the surcharge on their 2026 annual return due in April 2027. The SII’s Reconstruction Law Advisory Council is meeting monthly through March 2027 to shape regulations on the surcharge, VAT-exempt material certification, and depreciation guidelines. Draft regulations are expected by November 15, 2026, with final rules by January 31, 2027. Taxpayers claiming reconstruction benefits must file amended returns or specific forms by March 31, 2027, and improper claims under anti-abuse rules trigger a 100% penalty plus interest.
Sources: SII News: National Reconstruction Law Published | SII Resolution No. 146: VAT Refund Procedure | SII Resolution No. 141: Substitute Tax Form | SII News: Seven Circulars for Public Consultation | SII News: VAT Refund on Housing Sales | SII News: Reconstruction Law Advisory Council
Cooperative Tax Compliance — Advance Pricing Agreements and Collaborative Tax Compliance Agreements
On November 5, 2026, the SII announced the signing of multiple Advance Pricing Agreements (APAs) and Collaborative Tax Compliance Agreements (CTCAs) with major Chilean business groups under Law No. 21.532 on Tax Compliance. The agreements expand the Cooperative Tax Compliance Program and address transfer pricing methodologies for intercompany transactions in mining, retail, forestry, and financial services. Notable features include multi-year APAs with rollback provisions for up to three prior fiscal years, integration of BEPS Action 13 Country-by-Country Reporting data into APA analysis, and pre-agreed dispute resolution mechanisms referencing the Mutual Agreement Procedure under Chile’s tax treaties.
CTCAs impose enhanced transparency obligations, including real-time SII access to taxpayer ERP systems for risk assessment, quarterly compliance certification by independent auditors, and a dedicated SII relationship manager for each participating group. In return, participants receive reduced audit probability, binding guidance on contentious issues, and penalty mitigation for voluntary disclosures. Early adopters include mining groups such as Codelco and Antofagasta Minerals, retail conglomerates such as Falabella and Cencosud, and forestry holdings such as ARAUCO and CMPC.
APA applications for 2027 must be submitted by March 31, 2027. CTCA enrollment is open year-round subject to pre-qualification, and participants must submit annual compliance reports within 120 days of fiscal year-end. The SII will publish an updated list of APA-covered taxpayers and methodologies by January 15, 2027; breach of CTCA terms results in immediate program exit and a three-year ban on re-entry.
Sources: SII News: Cooperative Tax Compliance Strategy and APAs
Electronic Tax Document (DTE) Modernization — New Invoice and Dispatch Guide Requirements
The SII is advancing Chile’s e-invoicing modernization through updated technical requirements for electronic invoices and dispatch guides. Exempt Resolution No. 144 (October 23, 2026) sets new standards for documents supporting the transfer of movable tangible goods and revokes Exempt Resolution No. 154 of 2025. Separately, Exempt Resolution No. 146 (October 23, 2026) updates the XML schema from version 1.1 to 1.2, effective January 1, 2027. In addition, Exempt Resolution No. 144 (2024) standardizes DTE formats for specific industries, with full entry into force on May 1, 2027.
Key changes include mandatory buyer email addresses for B2C invoices, a new payment method code aligned with the Central Bank catalog, structured environmental tax breakdowns covering carbon tax, tire tax, and single-use plastics tax, mandatory customs declaration numbers for imported goods, and enhanced RUT and digital certificate validation. Dispatch guides must now include the transporter’s RUT and vehicle license plate. Resolution No. 144 (2024) adds mandatory fields for environmental taxes, digital services VAT, and transfer pricing documentation references, with real-time buyer RUT validation at the moment of issuance.
XML schema version 1.2 becomes mandatory on January 1, 2027, and documents issued under version 1.1 after December 31, 2026 will be rejected. Software providers must update certified solutions by December 31, 2026, with testing in the certification environment recommended by that date. Penalties include fines of 50 UTM per rejected document under Resolution No. 146 and fines of 100 to 1,000 UTM per document under Resolution No. 144 (2024), plus potential denial of VAT credits for recipients. The SII will conduct mandatory software provider testing in November 2026 and publish technical guides with webinars scheduled for November 2026 and March 2027.
Sources: SII News: Resolution 144 Entry into Force | SII News: Invoice and Dispatch Guide Updates | SII Resolution No. 144: Invoice Requirements
Secondary Regulatory & Regional Updates
- Trust Mechanism Enforcement: The SII reported that trust mechanisms under Article 42 of the Income Tax Law recorded a final balance exceeding CLP 2.4 trillion, with audits collecting over CLP 21 billion in unpaid taxes, interest, and penalties over three years. Trustees must file annual trust tax returns (Form 22) and report income attributed to settlers and beneficiaries; penalties range from 50% to 300% of omitted tax. SII
- SII–INAPI Joint Agenda on Intangible Assets: The SII and INAPI are developing a shared database of comparable transactions involving patents, trademarks, software, and trade secrets, with industry-specific valuation benchmarks and a joint circular expected in Q1 2027 to support transfer pricing audits under BEPS Actions 8–10 and Action 4. SII
- Campaign Against Undeclared Foreign Financial Accounts: The SII identified over 15,000 Chilean tax residents with undeclared foreign financial accounts exceeding CLP 3.2 trillion under CRS and FATCA. Invitation letters sent in November 2026 allow voluntary regularization that reduces penalties from 100%–300% to 10%–50% of omitted tax; amended returns for 2021–2025 are required. SII
- Tax Relief for Properties in Natural Disaster Zones: Owners in 45 catastrophe-declared communes receive 90-day extensions for territorial tax payments, interest and penalty condonation, 180-day suspension of enforcement actions, and accelerated fiscal reassessment for damaged properties. Reassessment requests are due within 60 days of the catastrophe declaration. SII
- Reconstruction Law Advisory Council: The SII council comprising tax advisors, academics, and business representatives will meet monthly through March 2027 to inform regulations on the corporate surcharge, VAT-exempt construction material certification, accelerated depreciation, and donation credit administration. Draft regulations are expected November 15, 2026, with final rules by January 31, 2027. SII
- Amendment to Snack Sales Intermediation System: Exempt Resolution No. 149 (October 27, 2026) modifies the 2009 authorization for the electronic intermediation system for snack sales, updating operational parameters to align with current e-invoicing and digital transaction requirements. The platform operator must adapt its system upon publication. SII Resolution
- Waivers in Tax Conciliation: Exempt Resolution No. 145 (October 23, 2026) sets general criteria for SII officials to evaluate waivers of tax debts, interest, and penalties in conciliation and extrajudicial settlement proceedings under Articles 132 bis and 132 ter of the Tax Code. SII Resolution
- Internal SII Organizational Restructuring: Exempt Resolution No. 143 (October 22, 2026) creates a new organizational area within the SII and modifies prior resolutions. The change is administrative and imposes no direct taxpayer compliance obligations. SII Resolution
- Academic Cooperation MoU: Exempt Resolution No. 153 (November 4, 2026) approves a Memorandum of Understanding among the SII, the University of Chile, and the Spanish Institute of Fiscal Studies for joint research and training in tax administration. No immediate taxpayer obligations arise. SII Resolution
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.