Transfer Pricing
Transfer pricing is one of the most technically complex and fiscally exposed areas of international tax law. The growing scrutiny exercised by the Chilean Internal Revenue Service (SII) over transactions between related parties requires taxpayers to have robust economic analyses, adequate documentation, and pricing policies that are consistent with the actual structure of the business group.
Added to this are formal reporting obligations and the penalties associated with non-compliance, making specialized advice essential — both from a technical and a strategic standpoint.
Our Services
Transfer Pricing Studies and Documentation
We prepare economic studies and the supporting documentation required to demonstrate that the conditions agreed upon in transactions between related parties comply with the arm’s length principle, as set forth in Article 41 E of the Income Tax Law (Decree Law 824).
Transfer Pricing Affidavits (SII Filings)
We assist in the preparation and submission of the transfer pricing affidavits (sworn statements) required by the SII, ensuring strict compliance with formal requirements and the deadlines established by the tax authority.
Design and Implementation of Transfer Pricing Policies
We support business groups in the design, review, and implementation of transfer pricing policies that align contractual terms with the functional reality of the parties, the group’s value creation, and the economic evidence supporting the reasonableness of the commercial conditions applied.
Valuation of Local Transactions (Tax Code — Decree Law 830)
We develop analyses and supporting documentation of arm’s length market values for transactions between related parties at the domestic level, in accordance with the provisions of the Tax Code (Decree Law 830), to strengthen the taxpayer’s position in the event of audits or assessments by the tax authority.
Transaction Structuring and Assessment
We provide specialized advice on the evaluation and structuring of transactions between related entities, both domestically and internationally, identifying risks and opportunities for improvement from a technical and economic perspective.
Defense and Representation before the SII and Courts
We represent our clients in audit proceedings, administrative inquiries, disputes before the SII, and litigation before the Courts of Justice, designing defense strategies to address transfer pricing adjustments, valuation challenges, and other contingencies arising from transactions with related entities.
Comprehensive Approach
Our advisory services cover the full life cycle of related-party transactions — from initial planning and documentation through to defense in contentious proceedings — providing our clients with a technically sound solution that is fully aligned with their business reality.