On August 18, 2026, TPC Group held a special event in Chile dedicated to the current key challenges in Transfer Pricing, which was fully attended in person and streamed online to professionals throughout Latin America.
One of the event’s main focuses was the presentation and analysis of the new Industry-Specific Profitability Indicators implemented by the Chilean Internal Revenue Service (SII), a tool designed to strengthen risk management, voluntary compliance, and the analysis of taxpayers’ profitability relative to industry benchmarks. The presentation on this initiative was led by Manuel Saavedra, Head of the International Risk Analysis Department at the SII, who detailed the technical scope and preventive approach of the tool.
The event also featured presentations by Soledad Recabarren, Chair of the Tax Commission of the Chilean Bar Association, and Antonio Faúndez, principal researcher at the UCV Tax Sustainability Observatory, who provided complementary perspectives from the legal and academic spheres on the current challenges of Transfer Pricing audits.
Launch of “Transfer Pricing: The Evidence That Decides”
The event also served as the venue for the regional launch of the book “Transfer Pricing: The Evidence That Decides,” presented by its authors: Carlos Vargas Alencastre, CEO of TPC Group, and Juan Pizarro Bahamondes, Chair of the Tax Commission of the Chilean Institute of Accountants.
During his remarks, Carlos Vargas Alencastre explained that the book compiles an analysis of 50 comparative case law examples across 13 jurisdictions, addressing key aspects of current Transfer Pricing disputes—such as economic substance, comparability, FAR analysis, DEMPE analysis, intra-group services, financing, intangibles, documentation, and the application of the arm’s-length principle — with the aim of offering a practical approach based on how these disputes are actually won and lost in court.
One of the central messages of the event was the growing importance of having not only formal documentation but also economic, contractual, and operational evidence capable of demonstrating the reality of transactions between related parties.
The book had already reached the top spot in Amazon Latin America’s rankings, underscoring regional interest in a practical approach to Transfer Pricing based on real-world cases and comparative case law.
An event with both in-person and regional reach
The event was attended by prominent officials from the Chilean tax sector, including Sebastián Vallebona, Undersecretary of the Treasury; Jorge Trujillo, Director of the Internal Revenue Service (SII); Carolina Saravia, Deputy Director of Tax Auditing at the SII; and Roberto Bustamante, National President of the Chilean Association of Accountants, whose participation reaffirmed the institutional significance of this conference for strengthening tax compliance in the country.
The high in-person turnout, which filled the venue to capacity, was complemented by the participation of professionals joining via the virtual broadcast, expanding the event’s reach to various countries in Latin America.
We at TPC Group would like to thank all the speakers, officials, professionals, clients, colleagues, and participants who took part in this event, as well as those who followed the online broadcast.
This event reaffirms our commitment to generating and disseminating specialized knowledge, promoting a vision of Transfer Pricing based on practical experience, technical analysis, and the real challenges companies face in an increasingly specialized tax audit environment.
🎥 Watch the full livestream of the event: