The Chilean Internal Revenue Service (SII) has published a new tool featuring industry-specific benchmark indicators for Transfer Pricing, aimed at distribution companies that purchase finished goods from related parties abroad. The initiative, part of the 2026 Tax Compliance Management Plan (PGCT), represents a pioneering milestone in Latin America and is based on the model used by the Australian Taxation Office (ATO).
Why the Focus Is on Distributors
Distributors account for 86% of the sales and purchases of finished goods reported for Transfer Pricing purposes in Chile, equivalent to more than $17.3 trillion in transactions. The SII’s sectoral analysis currently covers 57% of that total—$9.8 trillion—and in this initial phase covers six strategic sectors: vehicles and auto parts, technology, pharmaceuticals and medical supplies, food and non-alcoholic beverages, personal care and hygiene, and alcoholic beverages.
The tool is intended for taxpayers required to file Affidavit No. 1907, which reports transactions with related parties abroad—a requirement that applies to medium and large companies, as well as other taxpayers whose international transactions with related parties exceed $500 million annually.
How the Classification Model Works
The system compares the operating profitability of distribution companies with specific parameters for their economic sector, classifying them into three risk zones: low, medium, and high. Functionally, the model distinguishes three categories of distributors—routine, intermediate-function, and specialized—based on the premise that greater risk-taking and broader functions correspond to higher operating returns.
According to figures from the SII itself, the strategy covers a group of taxpayers representing between 25% and 30% of imports of goods for distribution in Chile, and the analyses conducted show that about one-third of the taxpayers evaluated present risk levels that warrant enhanced monitoring. Audit actions, however, will focus on a limited subset of cases that exhibit simultaneous indicators of financial and tax losses.
A preventive early-warning mechanism, not a substitute for legal analysis
The SII was explicit on a key point: these indicators do not replace existing legal obligations or comparability analyses. This is an early warning signal for companies to review their Transfer Pricing policies and take corrective measures before a potential issue leads to an audit. Taxpayers in the industries analyzed will also receive an email notifying them of the tool’s availability.
“Taxpayers will have early warning signals that will allow them to review their policies and take preventive measures when appropriate […] to mitigate their tax risks before they become a contingency or lead to an audit,” explained Jorge Trujillo, Director of the SII.
The agency also linked this tool to Advance Pricing Agreements (APAs), promoting their use as a mechanism to achieve greater legal and technical certainty in distribution transactions, within a tax relationship based on transparency and mutual trust.
At TPC Group, we help distribution companies with intercompany transactions in Chile assess their position in light of the SII’s new sector-specific indicators and strengthen their Transfer Pricing documentation with technically robust comparability analyses, thereby anticipating any signs of risk before they lead to an audit.
Source: Internal Revenue Service (SII)