Chile has aligned its tax transparency rules with the OECD’s BEPS Action 13 recommendations by implementing Country-by-Country Reporting (CbCR). These requirements are designed to provide tax authorities with a comprehensive view of the global operations and profit allocation of multinational enterprise (MNE) groups.

This guide outlines the CbCR obligations in Chile, including eligibility thresholds, filing procedures, deadlines, and associated penalties.

Regulatory Framework

• Authority: Servicio de Impuestos Internos (SII – Chilean Internal Revenue Service)
• Legislation:
  • Article 41 G of the Chilean Income Tax Law
  • Resolution No. 126 (2016) and amendments
  • SII Circular No. 23 (2017)
• International Engagement:
  • Chile is a member of the OECD Inclusive Framework on BEPS
  • Signatory to the Multilateral Competent Authority Agreement (MCAA) for the exchange of CbC reports

CbCR Filing Requirements

• Who Must File:
  • Ultimate parent entities (UPEs) resident in Chile with annual consolidated group revenue of CLP 750 billion or more in the previous fiscal year
  • Chilean subsidiaries or branches of foreign MNEs may also be required to file locally under certain conditions (e.g., if no exchange agreement exists with the jurisdiction of the UPE)
• CbCR Notification:
  • All Chilean constituent entities must notify the SII about the reporting entity
  • Deadline: by June 30 of the year following the end of the reporting fiscal year
• CbCR Submission:
  • Deadline: December 31 of the year following the fiscal year-end
  • Format: XML following OECD’s standard format
  • Submitted electronically via the SII online platform

Penalties for Non-Compliance

• Administrative penalties for:
  • Late filing: up to CLP 15 million
  • Incomplete or inaccurate information: up to CLP 30 million
  • Continued non-compliance may lead to further fines or audits

Important Considerations

• Chile also requires Master File and Local File documentation in line with BEPS Action 13
• CbCR is used for high-level transfer pricing and BEPS risk assessment
• Ensuring consistency of data across the group’s documentation is critical

Useful Resources

• Servicio de Impuestos Internos (SII): https://www.sii.cl
• OECD CbCR Guidance: https://www.oecd.org/tax/beps/country-by-country-reporting.htm