The Chilean Internal Revenue Service (IRS) on August 31 issued Resolution No. 101, which incorporates two new affidavits (‘Annual Master File Affidavit’ and ‘Annual Local File Affidavit’) regarding transfer pricing in Chile.
With these new information requirements, the IRS is aligned with the three-tiered transfer pricing documentation approach, contained in Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) project: the Country-by-Country Report (in force in Chile since 2016), the Master File, and the Local File. Accordingly, taxpayers domiciled or resident in Chile that carry out transactions with related parties abroad must deliver information and documentation to the tax authority in accordance with international standards.
