Innovations in Transfer Pricing Documentation in Chile

June 22, 2024

Chile has implemented several innovations in Transfer Pricing documentation to align with international best practices and improve tax transparency. The following are some of the main innovations in this area:  

Local Filing and Master Filing.  

Since 2016, Chile has required multinational companies that meet certain parameters to file a Local File (Local File) and a Master File (Master File). The Local File must contain detailed information on intra-group transactions affecting Chilean entities, while the Master File must provide an overview of the multinational group, including its organizational structure, business description, strategies and transfer pricing policies.  

Country by Country Report (Country-by-Country Reporting)  

Chile has also adopted the Country by Country Report (CbC), in line with OECD recommendations. This report, mandatory for multinational groups with consolidated revenues exceeding EUR 750 million, provides aggregated information on the global distribution of revenues, profits and economic activities of the group. The CbC enables tax authorities to identify potential Transfer Pricing risks and to make a more effective assessment of multinationals’ tax policies.  

Comparative Analysis and Benchmarking  

 Chilean regulations require comparative analysis and benchmarking studies to ensure that intra-group transactions are carried out at arm’s length. Companies must use comparable market data and apply internationally recognized Transfer Pricing methods to justify their Transfer Pricing policies.   

Audits and Taxation  

The Chilean tax authority has increased its transfer pricing audit and enforcement capabilities. Using advanced technological tools and risk analysis, reviews of intra-group transactions have been intensified to detect and correct possible deviations from transfer pricing rules.  

Advance Pricing Agreements (APAs)  

Chile has established a framework for Advance Pricing Agreements (APAs), allowing multinational companies to obtain certainty about the acceptance of their transfer pricing policies prior to entering into transactions. APAs provide greater legal certainty and reduce the risk of tax disputes.  


Innovations in Transfer Pricing in Chile reflect an ongoing effort to improve tax transparency and fairness. Multinational companies operating in Chile must keep up with these regulatory changes and ensure compliance with the new documentary requirements to avoid penalties and optimize their tax planning.