Chile’s Internal Revenue Service (SII) has issued Resolution No. 28 of 6 March 2025 on 6 March 2025, introducing a new approach for taxpayers to request advance pricing agreements (APAs).
This new resolution replaces previous resolutions from 2013 and 2022, amending the procedures to align with recent changes in the Law on Compliance with Tax Obligations (Law No. 21.713.
This includes establishing global best practices, such as prefiling meetings and an APA roll-back provision for applications up to 3 years before signing.
Resolution No. 28 outlines the APA procedure, including voluntary prior consultation, required documentation for an application, and processing of applications by the SII, which must be completed within 12 months of submission or when all the necessary information is provided.
Additionally, Resolution No. 28 covers APAs’ content, conditions for retroactive application, compliance monitoring, extensions, renewals, and terminations of APAs. The resolution also provides guidance related to bilateral or multilateral APAs with foreign tax authorities.
Resolution No. 28 takes effect on 6 March 2025.