This change will allow taxpayers to previously agree with the SII how to value their intercompany transactions.
As a result of the changes incorporated in Law No. 21,713 on compliance with tax obligations, the Internal Revenue Service (SII) – through Exempt Resolution No. 28 of 2025 – updated the procedure established for the filing of Advance Transfer Pricing Agreements (APAs).
This update will allow taxpayers to agree in advance with the SII how to value their intercompany transactions.
What are they and why do they matter?
Transfer Pricing rules seek to ensure that transactions between related companies (e.g. subsidiaries of the same group) are carried out at market values.
This allows:
- Transparency in taxation.
- Reduction of the risk of adjustments by the SII.
- Avoidance of double taxation.
We also share some relevant data in this regard:
- 17 APAs have already been signed, which has generated an additional collection of more than USD 647 million.
- The APAs are valid for 5 years, and can be applied retroactively up to 3 previous fiscal years.
- This tool is expected to continue to grow, promoting tax certainty and tax efficiency.
Do you carry out transactions with related parties? Solve your doubts and let’s talk about how to be prepared. Contact our Tax team:
Rodrigo Albagli | Partner | ralbagli@az.cl
Álvaro Rosenblut | Partner | arosenblut@az.cl
Andrea Bobadilla | Director Tax Group | abobadilla@az.cl
Valentina Herrera | Associate | vherrera@az.cl
Javiera Melo | Associate | jmelo@az.cl
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