In order to ensure compliance with tax obligations and promote greater tax transparency, the Chilean Internal Revenue Service (Servicio de Impuestos Internos – SII) has established five Affidavits (Declaraciones Juradas – DJ) related to Transfer Pricing. These affidavits must be filed based on the characteristics and transactions of each taxpayer. Below is a description of each affidavit, together with the criteria that determine the filing requirements and the corresponding deadlines:

1. Transfer Pricing Affidavit No. 1907

2. Global Tax Characterization Affidavit No. 1913

3. Country-by-Country Report No. 1937

4. Master File No. 1950

5. Local File No. 1951

6. Annual Affidavit No. 1907

Who Must File Affidavit No. 1907?

• Taxpayers who, as of December 31 of the year being reported, belong to the Medium-Sized Enterprises or Large Enterprises segments and who, during that year, carried out transactions with related parties not domiciled or resident in Chile, in accordance with the provisions of Article 41 E of the Income Tax Law;

• Taxpayers who are not included in the segments referred to above and who, during the reporting period, carried out transactions with related parties not domiciled or resident in Chile for amounts exceeding CLP 500,000,000 (five hundred million Chilean pesos), or their equivalent based on the exchange rate parity between the Chilean peso and the foreign currency in which such transactions were carried out, as in force as of December 31 of the year being reported, according to the publication issued by the Central Bank of Chile;

• Taxpayers not classified in the above segments who carry out transactions with persons domiciled or resident in a territory or jurisdiction subject to a preferential tax regime, as referred to in Article 41 H of the Income Tax Law.

The transactions to be reported include those carried out during the commercial year being reported, as well as those maintaining outstanding balances during the same period. Where taxpayers carry out more than one type of transaction with foreign related parties, or the same transaction with different related counterparties, each transaction must be reported in separate records. Conversely, where taxpayers carry out more than one transaction of the same type during the reported year with the same foreign related party, such transactions must be reported in a single record.

Types of Transactions to Be Reported

Imports, exports, loans, provision of services, payments for the use of intangibles, business reorganizations or restructurings, and any transaction involving foreign related parties or companies domiciled in countries with preferential tax regimes.

Filing Deadline:
Up to June 30, 2025. An extension may be requested.

Annual Global Tax Characterization Affidavit No. 1913

Who Must File Affidavit No. 1913?

• Large Enterprises segment

• Registry of Large Taxpayers

What Information Does the SII Require?

• Information related to the business group or corporate holding

• Information related to business reorganizations

• Information related to financial instruments and/or derivative contracts

• Information related to profit before tax

• Information related to capital assets

• Information related to international transactions

Filing Deadline:
Must be filed by June 30, 2025.

Annual Affidavit No. 1950 – “Master File”

Who Must File Affidavit No. 1950?

Taxpayers meeting any of the following conditions must file the “Annual Master File Affidavit” with the Internal Revenue Service using Form No. 1950.

In addition, an annex to Form No. 1950 containing descriptive information regarding the Annual Master File Affidavit must be filed, together with all documents indicated therein:

• The parent or controlling entity of a Multinational Enterprise Group (hereinafter also referred to as the “MEG”) that is tax resident in Chile, provided that the consolidated revenues of all entities comprising the group in Chile and abroad, as of December 31 of the year being reported, amount to at least EUR 750,000,000 (seven hundred fifty million euros) at the closing of the consolidated financial statements, based on the exchange rate observed as of January 1, 2015, as determined by the Central Bank of Chile in accordance with No. 6 of Chapter I of the Compendium of International Exchange Regulations; or

• An entity belonging to the MEG that is tax resident in Chile and that has been designated by the parent or controlling entity of the group as its sole surrogate entity for purposes of filing the “Country-by-Country Report” in its country of tax residence, on behalf of the parent or controlling entity.

Filing Deadline:
The last business day of June of each year, with respect to transactions carried out during the immediately preceding commercial year. A one-time extension of up to three months may be requested, in accordance with the provisions of No. 6 of Article 41 E of the Income Tax Law. The extension must be requested prior to the expiration of the original deadline, specifying the period for which it is requested.

Penalties:
Non-compliance will be sanctioned in accordance with No. 6 of Article 41 E of the Income Tax Law.

Annual Affidavit No. 1951 – “Local File”

Who Must File Affidavit No. 1951?

The SII provides that taxpayers who, as of December 31 of the year being reported, meet the following cumulative conditions must file the “Annual Local File Affidavit” using Form No. 1951. Additionally, they must file the annex to Form No. 1951 containing descriptive information regarding the Annual Local File Affidavit, together with all documents indicated therein:

• They belong to the Large Enterprises segment, in accordance with the criteria established in Exempt Resolution SII No. 76 dated August 23, 2017;

• Their parent or controlling entity of the Multinational Enterprise Group was required to file the Country-by-Country Report with the Internal Revenue Service or another Tax Authority for the relevant tax year; and

• During that year, they carried out one or more transactions with related parties not domiciled or resident in Chile, in accordance with Article 41 E of the Income Tax Law, for amounts exceeding CLP 200,000,000 (two hundred million Chilean pesos), or their equivalent based on the exchange rate parity in force as of December 31 of the year being reported, as published by the Central Bank of Chile.

Filing Deadline:
The last business day of June of each year, with respect to transactions carried out during the immediately preceding commercial year. A one-time extension of up to three months may be requested, in accordance with No. 6 of Article 41 E of the Income Tax Law. The extension must be requested prior to the expiration of the original deadline, specifying the period for which it is requested.

Penalties: Non-compliance will be sanctioned in accordance with No. 6 of Article 41 E of the Income Tax Law.