A launch with a technical and regional perspective
On July 14, 2025, TPC Group held the official presentation of the book “Transfer Pricing in Chile and Latin America”, a reference work prepared by Carlos Vargas Alencastre, founding partner and CEO of TPC Group, and Juan Pizarro Bahamondes, president of the Tax Commission of the Chilean Association of Accountants, director of Tax Capital Advanced and partner of TPC Group.
Image: Book “Transfer Pricing in Chile and Latin America” (First edition – 2025)
Source: Prepared by the author
During the event, Carlos Vargas Alencastre emphasized:
“This book was born out of the need to address tax sustainability as a central axis in tax planning, especially in a regional context with increasingly demanding rules.”
Image: Carlos Vargas Alencastre
Source: Prepared by the authors
Image: Carlos Vargas Alencastre and Juan Pizarro Bahamondes during the presentation event
Source: Prepared by the author
Reflections from the authorities, academia, and business
The event featured prominent commentators from the national tax arena, whose contributions enriched the analysis:
- Manuel Saavedra Cárdenas, Head of the International Risk Analysis and Business Groups Department of the Internal Revenue Service (SII), stated:
“From the tax administration, we want taxpayers to understand that transfer pricing obligations are not merely formalities, but part of tax fairness control.”
- Soledad Recabarren G., President of the Tax Commission of the Bar Association, highlighted:
“Transparency and adequate support for transfer pricing studies are now essential requirements in the face of more technical and specialized tax audits.”
- Antonio Faundez Ugalde, Doctor of Law and Professor of Tax Law at the Pontificia Universidad Católica de Valparaíso (PUCV), noted:
“The Chilean regulatory framework has evolved and now requires a more robust legal and economic justification for related-party transactions.”
- Pablo Hernández Bustos, Head of Taxes & Report at DP World Chile, added:
“The private sector needs clarity, but also technical flexibility to adapt to these new obligations without losing operational efficiency.”
Image: Presentation and technical dialogue during the launch event
Source: Own elaboration
A technical and up-to-date work for today’s challenges
The book contains 13 chapters and 4 case studies that analyze the approaches adopted by various Latin American jurisdictions in terms of taxation, filing thresholds, transactions with tax havens, and documentation requirements (such as the Benefit Test). It also includes a compilation of recent circulars and resolutions issued by the Chilean Internal Revenue Service.
During the presentation, emphasis was placed on the need for robust documentation and detailed functional analysis, considering that many tax administrations are increasing the level of technical review of intercompany transactions.
As Juan Pizarro Bahamondes pointed out:
“In this text, we not only analyze the law, but also how companies should prepare to be audited under a new standard of reasonableness and economic substance.”
Conclusion
This publication is an essential tool for professionals, companies, and tax authorities. In the words of Carlos Vargas Alencastre:
“The defense of transfer pricing is not based solely on tables or methods, but on a coherent, documented, and legally valid economic narrative.”
Source: Prepared internally based on the launch event for the book “Transfer Pricing in Chile and Latin America,” TPC Group, July 2025.
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