Chile: Transfer pricing guidance for distributors
Outlining criteria for analyzing the functional characterization and profitability of Chilean entities that perform distribution functions within multinational groups
The Internal Revenue Service (SII) has published a specific section on distributors on its transfer pricing portal, outlining criteria for analyzing the functional characterization and profitability of Chilean entities that perform distribution functions within multinational groups. While the publication neither amends the law nor establishes a safe harbor regime, it provides significant indications regarding how the SII might review these structures during audits or advance pricing agreement (APA) processes.
In addition, although the guidance does not formally implement Pillars One or Two, it demonstrates a convergence with the principles underlying the OECD/BEPS project: (1) allocating profits where relevant functions are performed; (2) recognizing the importance of market jurisdictions; and (3) ensuring that local entities receive remuneration commensurate with their economic contribution.
Read a June 2026 report (Spanish) prepared by the KPMG member firm in Chile