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Transfer Pricing

Companies that carry out transactions with related companies or residents in tax havens must submit their Transfer Pricing Study to the SII on July 1, supporting the nature of their relevant transactions.

The Study must contain the necessary economic and legal support to prove that the transactions are being agreed at market value. Our team of experts will assist you with:

  • Optimization and planning of intra-group transactions
  • Preparation of Informative Affidavit
  • Transfer pricing risk assessment
  • Support in documentation and selection of transfer pricing method
  • Supporting documentation and affidavits
  • Price range study on specific operations
  • Support in transfer pricing audits

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    Advantages of the Transfer Pricing Study Obligated contributors Fines and Penalties
    • Document how the prices, values or returns of the transactions subject to the transfer pricing scope were determined.
    • Instrument of tax, financial and economic analysis to comply with the filing of the 1907 and 1913 tax returns
    • The taxpayer, upon being summoned by the SII, in the administrative citation stage, must provide all the background to support the correct application of its transfer pricing.
    • The term given by the Law for the attendance to the citation is one month, therefore the transfer pricing study must be prepared in advance.
    • Taxpayers classified as Medium-sized or Large Companies and who have carried out transactions with related parties abroad.
    • Taxpayers who have carried out transactions with related parties abroad, including also those transactions carried out with persons domiciled or resident in a territory or jurisdiction with a preferential tax regime (tax havens), in both cases, for amounts exceeding $ 500,000,000 (five hundred million Chilean pesos).
    • If the taxpayer cannot prove that the transactions with its related parties have been carried out at normal market prices, values or returns, the SII has the power to determine adjustments.
    • Failure to file the 1907 affidavit, or its erroneous, incomplete or untimely filing, will be punished with a fine of 6 to 30 million Chilean pesos (not exceeding the equivalent of 15% of the taxpayer’s equity or 5% of the effective capital, whichever is greater).
    • If the declaration presented is maliciously false, the taxpayer will be sanctioned with a fine of 50% to 300% of the value of the tax evaded.
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