The Chilean Internal Revenue Service (SII) reported that in 2025 it conducted 125 audits related to Transfer Pricing, generating total revenue of CLP 94,045 million, equivalent to more than US$100 million. The average revenue per audit exceeded CLP 752 million, while CNN Chile estimated an average of more than US$823,000 per case.
Where was the revenue concentrated?
General Transfer Pricing audits, which involve a comprehensive review of a company’s operations, accounted for the largest amount collected: CLP 49,083 million, corresponding to 33 cases, equivalent to 52.2% of the total.
In second place were audits related to financial transactions, with CLP 30.439 million collected in 28 cases, representing 32.4%. Finally, audits related to other transactions generated CLP 14.524 million in 64 cases, equivalent to 15.4% of the total.
Together, general audits and those related to financial transactions accounted for 84.6% of the revenue collected in 2025.
How does the SII identify cases to audit?
The SII has strengthened its audit strategy through a risk-based approach and data analysis tools. Among the main factors considered are recurring losses, profit margins outside market ranges, transactions with low-tax jurisdictions, significant changes in business structure, and discrepancies between financial information and tax returns.
To focus audits on transactions involving greater complexity and tax risk, the authority cross-references information from tax returns, financial statements, and automatic exchanges of information with other tax administrations, including Country by Country Reports “Country by Country Report”.
A Significant Volume of Related-Party Transactions
According to information published by the Central Bank and the data contained in Tax Return No. 1907 on Transfer Pricing, 36% of goods exports during the 2024 fiscal year consisted of transactions with related companies, totaling CLP 33.7 trillion.
Likewise, 32% of domestic imports came from foreign related parties, totaling CLP 23.81 trillion. These figures reflect the significance of intra-group transactions within Chile’s international trade and explain the SII’s growing focus on this area in its tax audits.
An increasingly broad audit strategy
These figures are part of the SII’s Tax Compliance Management Plan (PGCT), which considers transactions between companies within multinational groups to be a priority area.
The main areas reviewed by the authority include the sale of goods, intragroup services, loans and financial transactions, royalties for the use of intellectual property, corporate reorganizations, and transactions related to intangible assets.
In addition to audit activities, the SII has been complementing its strategy with cooperative compliance tools, such as Advance Pricing Agreements (APAs) and the publication of statistical indicators on international transactions and Transfer Pricing.
At TPC Group, we assist companies with intercompany transactions in Chile in preparing and providing technical support for their Transfer Pricing policies, taking into account the risk factors used by the SII to target its audits and helping them identify potential contingencies before they result in high-impact tax adjustments.
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