Chile Transfer Pricing Documentation Requirements
Chile administers its documentation regime through affidavits filed with the tax authority. Large taxpayers and groups within the Country-by-Country threshold file a Local File affidavit and a Master File affidavit, while a separate annual transfer pricing affidavit is due by the last business day of June.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Form F1950
Required | Chilean parent or controlling entity of an MNE group with consolidated turnover ≥ EUR 750m | By the affidavit deadline | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES / EN | Yes (10 to 50 annual tax units) |
Local File Form F1951
Required | Large taxpayers, members of CbC-reporting groups, and entities transacting under Article 41 E | By the affidavit deadline | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES / EN | Yes (10 to 50 annual tax units) |
TP affidavit Form F1907
Annual filing | Taxpayers within the transfer pricing rules | Last business day of June | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Chile administers its documentation requirements through a set of affidavits. The Master File affidavit, Form F1950, is required of a Chilean parent or controlling entity of a multinational group with consolidated turnover of at least EUR 750 million. The Local File affidavit, Form F1951, is required of entities listed as large taxpayers, of entities whose parent had a Country-by-Country reporting obligation, and of Chilean entities transacting with foreign parties under Article 41 E of the income tax law. A broader documentation duty applies to taxpayers below the F1951 thresholds, who must maintain local transfer pricing documentation and produce it within 15 days of a request.
Distinctive features of the Chilean regime
Two features distinguish the Chilean regime. The first is the affidavit-based structure, under which the Local File and Master File are discharged through formal returns rather than documents held purely on request, supplemented by Form 1913, a global characterisation of the taxpayer carrying transfer pricing questions, filed before the income tax return. The annual transfer pricing affidavit, Form F1907, is filed by the last business day of June, with a one-time three-month extension available. The second is the substance-over-form principle: the tax authority can challenge not only whether a price is at arm’s length but also the effectiveness and economic substance of the transaction itself. There is no general safe harbour, although the royalty rate on a related-party transaction is capped for deductibility at 4 percent of sales.
Benchmarking and comparables
Foreign comparables are accepted in the absence of local comparables where they are similar in functions, assets, and risks. Single-year testing is recommended for the tested party, while multi-year analysis is usual for the comparable range and may be applied to the tested party where the economic reasons are explained. The rules do not specify the frequency of a fresh search, and practice follows the OECD approach. The general limitation period is three years from the date the tax was due, extending to six years where no return is filed or a return is found to be false.
Frequently asked questions
What documentation applies to a Chilean taxpayer below the F1951 thresholds?
It must still maintain local transfer pricing documentation supporting its pricing and produce it within 15 days of a request, even though it is not required to file the F1951 Local File affidavit.
Can the Chilean tax authority challenge the substance of a transaction?
Yes. The Chilean rules apply substance over form, so the authority can challenge not only whether the price is arm's length but also the effectiveness and economic substance of the transaction itself.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.