Circular No. 10/2025, which replaces Circular No. 29/2013, provides new systematic instructions for the tax authority to make transfer pricing adjustments effective November 1, 2024.
The new instructions, which are in line with amendments included in Law No. 21,713:
- Expressly include use of the interquartile range
- Allow taxpayers to make self-adjustments
- Set forth the conditions under which the tax authority can review business reorganizations or restructurings
- Provide guidance regarding advance pricing agreements (APAs)
In addition, Resolution No. 6/2025, which replaces Resolution No. 67/2013, establishes new procedures for processing requests for transfer pricing adjustments.
Read a February 2025 report (Spanish and English) prepared by the KPMG member firm in Chile
Other direct and indirect tax-related topics discussed in this report include:
- Law No. 21,713
- Access to taxpayer banking information
- Adjustments and late payment interest
- Obligation to report credits received in account
- Instructions on amendments to the value added tax (VAT) law
- Unified audit procedure for business groups and tax sustainability
- Instructions on amendments to rules on indirect sales, passive income, and preferential tax regime
- Obligation to provide printed representation of electronic receipts and electronic payment vouchers
- Effects of the death of a partner and VAT exemption for professional partnerships
- Tax avoidance in association contracts or joint accounts (binding consultations)
- Tax avoidance in the assignment of purchase option in a leasing contract (non-binding consultation)