Chile’s SII (Servicio de Impuestos Internos – Internal Revenue Service) continues to strengthen its tax compliance strategy through the 2026 PGCT (Plan de Gestión de Cumplimiento Tributario – Tax Compliance Management Plan), incorporating enhanced capabilities in tax enforcement, data analysis, and the monitoring of complex transactions.
Within this new approach, international transactions and multinational groups take on special significance, increasing companies’ exposure to Transfer Pricing audits.
The 2026 PGCT reflects a trend toward more technology-driven, coordinated, and tax-risk-management-based enforcement.
International Taxation and Strengthened Enforcement
The SII document highlights the strengthening of capabilities regarding international taxation, multinational groups, and cross-border transactions to improve the detection of tax risks and the proper application of tax regulations.
Likewise, the PGCT incorporates new tools related to:
- Big data analysis,
- Artificial intelligence,
- Automated monitoring,
- and cross-jurisdictional enforcement. .
This scenario increases the importance of robust Transfer Pricing policies and technically sound documentation.
Risk-Based Examination
The MGCT (Modelo de Gestión de Cumplimiento Tributario – Tax Compliance Management Model) implemented by the SII consists of five stages:
- Identify
- Analyze
- Prioritize
- Address
- Evaluate
The approach utilizes Big Data and automated analysis to identify tax compliance gaps and target audits at higher-risk taxpayers.
Regarding Transfer Pricing, it implies a greater capacity to review:
- Related-party transactions,
- Multinational structures,
- International tax planning,
- And the economic consistency of intra-group transactions.
Advance Pricing Agreements (APA) and Tax Transparency
The 2026 PGCT also highlights the advancement of Advance Pricing Agreements (APAs) as a preventive tool for tax compliance.
According to the document, since 2019, the SII has signed 23 Transfer Pricing agreements, including Bilateral Advance Pricing Agreements (BAPAs).
It demonstrates the tax administration’s increasing focus on enhancing mechanisms for tax certainty and preventive controls in international transactions.
Multi-jurisdiction and New Technological Capabilities
Another relevant aspect is the expansion of cross-jurisdictional enforcement capabilities nationwide starting in 2026.
This measure will enable enforcement teams to audit taxpayers located in different regions of the country, facilitating more efficient and coordinated reviews.
Additionally, the strategic use of data and AI strengthens the SII’s capabilities to:
- Identify risk patterns,
- Detect tax inconsistencies,
- And improve traceability of complex transactions.
The PGCT 2026 confirms that Chile is moving toward a more sophisticated, digital, and risk-based tax enforcement model.
For multinational companies, this scenario increases the need to strengthen their Transfer Pricing policies, ensure robust technical documentation, and maintain economic consistency in their international operations. Tax transparency, the technology, and international cooperation will continue to shape the evolution of tax enforcement in the region.
At TPC Group, we have Transfer Pricing specialists ready to support companies in assessing tax risks, preparing technical documentation, and complying with international tax obligations amid increasingly demanding regulatory environments.
Source: SII