On July 13, 2026, the Internal Revenue Service (SII) and the Chilean Copper Commission (Cochilco) held a joint conference specifically aimed at promoting the use of Advance Transfer Pricing Agreements (APAs) in the mining industry, with the participation of authorities, tax specialists, and representatives from major companies in the sector, including Codelco and Lundin Mining. The event, organized in partnership with the National Mining Society (SONAMI) as host, marks the first time the SII has coordinated a joint agenda with the sectoral authority for copper specifically aimed at promoting this mechanism among the country’s leading mineral exporters.
Why Mining Is a Focus for Both Institutions
During the meeting, the SII and Cochilco presented figures that explain why the mining sector receives this special attention: mining accounted for 13.1% of Chile’s Gross Domestic Product in 2025 and 59% of the country’s exports, while copper mining alone contributed 10% of tax revenue. The authorities emphasized that the high value of transactions in the sector, the extent of its international supply chains, and the impact of technical variables that can substantially alter the final price of minerals—factors we have already addressed when analyzing the CUP method in the valuation of concentrates—mean that an APA provides particularly high value in this industry by offering advance legal and tax certainty regarding the pricing methodology to be applied.
Cochilco’s Technical Role and Its Explicit Limits
A key point that the authorities themselves took care to clarify during the conference is the exact scope of Cochilco’s involvement in this process. The Commission contributes its technical expertise on the copper and other minerals markets—including statistics, sector studies, and oversight of export trading conditions—information that can support comparability analyses in the sector. However, it was made explicit that Cochilco does not negotiate, sign, or resolve APAs: the review, negotiation, decision-making, monitoring, renewal, or termination of these agreements falls exclusively within the purview of the SII, and Cochilco’s collaboration is limited to the use of public, aggregated, anonymous, or legally shareable information. This distinction is important for any mining company considering initiating the process: the SII remains the sole point of contact and the party ultimately responsible for an APA.
What Specific Transactions Might Be Covered
Among the transactions that the authorities identified as potentially covered by an APA in the sector, the following were explicitly mentioned: the purchase or sale of copper and other minerals between related parties; payments to affiliated traders, distributors, or marketers; intragroup services and costs; and royalties for the use of intangible assets. This broad scope suggests that the SII is not conceiving the mechanism solely for the sale of the mineral itself, but rather for the entire set of intercompany relationships that typically accompany the marketing chain of a mining company with an international structure.
A Figure That Continues to Grow
According to figures presented by the SII itself during the conference, Chile has 24 Transfer Pricing agreements in place as of July 2026, positioning it as one of the Latin American countries with the highest number of agreements signed in accordance with OECD standards. The authorities framed this initiative as part of a broader preventive agenda aimed at anticipating risks and reducing disputes, expressly stating that the joint technical work will be limited to the main commercial variables of mineral operations, without establishing mandatory prices or replacing the individual analysis that each taxpayer is required to perform.
At TPC Group, we assist companies in Chile’s mining sector with the evaluation and preparation of applications for Advance Transfer Pricing Agreements, taking into account both the technical requirements set by the SII and the specific market conditions that Cochilco has identified as relevant for the sector’s comparability analysis.
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