The Chilean Internal Revenue Service (SII) has introduced industry-specific benchmark indicators enabling distribution companies to self-assess their transfer pricing risk profile and achieve greater voluntary compliance through a preventive, OECD-aligned framework.
Chile’s Internal Revenue Service (SII) announced, on 23 June 2026, that it has unveiled industry-specific benchmark indicators enabling distribution companies to evaluate their transfer pricing compliance and identify potential tax risks. The initiative, previously committed to in the 2026 Tax Compliance Management Plan (PGCT), represents a significant step toward preventive tax governance aligned with OECD standards.
The tool adapts methodologies successfully implemented by OECD member countries, including Australia, which have leveraged profitability indicators to strengthen transparency in related-party transactions.
How the self-assessment framework operates
The tool targets companies required to file Transfer Pricing Affidavit No. 1907, particularly those conducting international transactions with related parties exceeding USD 500 million annually. By measuring operating profitability against sector-specific thresholds, the system categorises taxpayers into three risk zones—low, medium, and high—enabling early identification of compliance issues before audits occur.
The underlying data reflects substantial market scope: distributors represent 86% of finished goods sales globally, valued at over USD 17.3 trillion. The SII’s current analysis encompasses 57% of this segment, approximately USD 9.8 trillion, representing between 25% and 30% of Chile’s goods imports for distribution.
The framework functionally classifies distributors into three operational categories—routine, intermediate, and specialised—reflecting that increased risk assumption and complexity should correlate with higher operational returns.
Sectoral coverage and risk monitoring
The framework initially covers six strategic sectors: vehicles and spare parts, technology, pharmaceuticals and medical supplies, personal care products, food and beverages, and alcoholic beverages. Preliminary findings show that one-third of evaluated taxpayers exhibit risk levels requiring enhanced monitoring, with audit resources directed toward cases displaying simultaneous financial and tax loss indicators.
Eligible taxpayers will receive electronic notifications advising them of the tool’s availability, allowing them to conduct voluntary self-assessments and implement corrective measures proactively. According to SII Director Jorge Trujillo, this approach provides “early warning signals that allow taxpayers to review their policies and adopt preventive measures when appropriate,” mitigating tax risks before they escalate into contingencies or audits.
Legal certainty and voluntary compliance
The SII emphasised that these indicators function as preventive warning mechanisms rather than replacements for existing legal obligations or comparability analyses. Companies are encouraged to pursue Advance Pricing Agreements (APAs) to strengthen their legal certainty and foster transparent tax relationships with authorities, reinforcing the administration’s commitment to cooperation-based compliance policy.
