SII issued Resolution Ex. SII No. 208-2025, effective 1 January 2026, updates the large taxpayer list, revises key definitions, and sets criteria and procedures for classification, while retaining the SII Director's discretion to include critical entities.
Chile’s tax authority (SII) published Resolution Ex. SII No. 208-2025 of 30 December 2025 on its website and entered into effect on 1 January 2026.
The Resolution updates the large taxpayer list, including taxpayers no longer classified as such and revised the definitions of “business group,” “multinational business group,” and “key economic sector for tax purposes.” It also outlines the specific legal and financial criteria used to classify entities, such as annual sales exceeding 75 million UF or belonging to multinational groups. The resolution details the department’s jurisdictional authority to oversee these high-impact organisations across the entire national territory.
The Resolution also establishes administrative procedures for adding or removing companies from the list, ensuring consistent oversight during corporate transitions.
SII used the following criteria to qualify taxpayers as large taxpayers:
- Revenue threshold: Belonging to a business group whose Chilean resident companies have combined annual sales or income equal to or exceeding 75,000,000 UF (Unidades de Fomento) over the last three commercial years.
- Multinational reporting: Being part of a multinational business group where the parent company is a Chilean tax resident and was required to file a “Country-by-Country Report” in at least one of the last three years.
The Director of the SII retains the authority to include or exclude taxpayers, regardless of the strict criteria outlined above. The Director may include entities with relevant positions in critical economic sectors, such as banking and mining, even if they do not meet the standard revenue thresholds. In addition, taxpayers performing operations in Chile that are included in a “Country-by-Country Report” filed abroad may also be added to the list.
Once classified, a taxpayer will generally remain on the list for a minimum of three years to ensure the quality of internal processes. If a Large Taxpayer undergoes a merger, division, or transformation, they typically remain on the list as long as their Tax ID (Rol Único Tributario) does not change.
