On 31 August 2020, the Internal Revenue Service (SII) published a Resolution No. 101, which establishes the obligations for companies to submit master file (Form 1950) and local file (Form 1951) respectively. The Resolution includes both Forms. The new requirements generally follow the recommendations of the OECD’s base erosion and profit shifting (BEPS) project. The submission deadline of both master file and local file is the last business day of June of the year following the reporting year, and the deadline may be extended only once, for up to three months. The language of both master file and local file may be in Spanish or English. Again, both of the Forms requires to be submitted electronically through SII website.

Obligations to submit master file

According to the Resolution, taxpayers who meet any of the conditions that are indicated below, must file by using Form 1950 to the SII:

  • the parent entity of an MNE group, which has tax residence in Chile, to the extent that the consolidated group revenue of the MNE group is at least EUR 750 million as of 31 December of the reporting year; or
  • an entity that belongs to such an MNE group, which has tax residence in Chile and has been designated by the parent or controlling entity of the MNE group as a surrogate parent entity for the submission of a CbC report.

Obligations to submit local file

Under this new Resolution, Chilean resident companies require to file local file if they meet any of the conditions below:

  • In accordance with the Resolution No. 76 of 23 August 2017, the Chilean resident company must be qualified as a large company on the basis of total sales.
  • The taxpayer belongs to an MNE group, the parent or controlling entity of which has been required to submit a CbC report to the SII or foreign tax administration for the respective year; and
  • Under Article 41 E of the Chilean income tax law, the taxpayer’s transaction with foreign related parties for amounts greater than or equivalent CLP 200 million as of 31 December of the reporting year as published by the Central Bank of Chile.