Chile master file and local file requirements (2026)

What transfer pricing returns does Chile require in 2026?

Four sworn returns, each with its own trigger, all due on the last business day of June for the prior commercial year. That is 30 June 2026 for commercial year 2025. Nothing here is held for request, which is the single biggest difference between Chile and most of its neighbours.

Filing any of the four between 1 July and 30 September 2026 counts as an automatic three month extension request, with no separate application, according to the tax authority's notice of 18 June 2025^[1].

What are Chile's latest transfer pricing rules?

Chile rewrote its transfer pricing rules in 2024. The reform was published on 24 October 2024 and took effect on 1 November 2024^[2], and the tax authority set out how it reads the new text in a circular issued in 2025^[3].

Two changes matter in practice. The interquartile range became the statutory test for whether a price is at arm's length, and taxpayers gained a self-adjustment route that lets them correct prices before an audit rather than after one. Both apply from 1 November 2024.

Who counts as a related party in Chile?

Any entity that participates directly or indirectly in the management, control, capital, profits or income of another. The statutory test^[4] sets no ownership percentage at all, so the question is participation and control rather than a stake you can count.

Two categories are related whatever the ownership. Permanent establishments are in scope by definition. So is any counterparty in a jurisdiction Chile lists as preferential, which pulls in transactions with companies nobody in the group owns.

What are Chile's master file requirements?

The master file, Form 1950, applies to a Chilean resident parent of a group with consolidated revenue of at least EUR 750,000,000, and to a Chilean group entity designated to file the country-by-country report. It is due on the last business day of June for the prior commercial year, so 30 June 2026 for commercial year 2025.

The EUR 750,000,000 test is the combined revenue of every group entity, in Chile and abroad, measured at the consolidated financial statement close. The resolution that created the form^[5] fixes the euro conversion at the exchange rate observed on 1 January 2015, so the rate does not move with the market. The file itself covers the group: its structure, its business, its intangibles and its financing.

What are Chile's local file requirements?

The local file, Form 1951, is a return in its own right, filed separately from the master file through the online returns system with its annexes submitted independently. It applies only where all three of these hold as of 31 December: the entity sits in the large taxpayer segment, its parent has to file a country-by-country report, and its non-resident related party transactions exceed CLP 200,000,000 in the year.

All three have to be true together. An entity below the large taxpayer segment files no local file, and neither does one below the transaction threshold, however large its parent. The CLP 200,000,000 test uses the year end exchange rate for amounts held in other currencies.

Who must file Form 1907?

Three groups. Medium and large enterprises with non-resident related party transactions. Any taxpayer transacting with a jurisdiction Chile lists as preferential. And any other taxpayer whose non-resident related party transactions exceed CLP 500,000,000 in the year, according to the Form 1907 instructions^[6].

Form 1907 is the headline annual disclosure of related party transactions. It was first introduced in 2013 and its current format was set in 2022. It falls on the same 30 June date as the other three, with the same extension window behind it.

Does Chile require country-by-country reporting?

Yes, on Form 1937, for groups with revenue of at least EUR 750 million in the 12 months before the tax period, filed by the Chilean resident parent. The country-by-country rules^[7] have been in force since 2016, and the first filing was made in 2017 for commercial year 2016.

The notification mechanic is what catches foreign parents out. Where the group files its report elsewhere through a designated entity, the Chilean entity still owes a delegation notice, and it has to land within the 30 calendar days before the report deadline. Miss that window and the sworn statement penalty applies to a return the Chilean entity was never going to file itself.

When are Chile's transfer pricing returns due in 2026?

All four fall on 30 June 2026 for commercial year 2025. The extension is automatic and needs no application: filing between 1 July and 30 September 2026 is treated as a three month extension request. The delegation notice runs on a different clock entirely.

What language must the documentation be in?

Spanish or English, both accepted for the master file and the local file. The tax authority may still require a Spanish translation in specific cases. The thresholds do not follow the filing language: the group test stays in euros, the transaction tests stay in Chilean pesos, and the penalties run in annual tax units.

What benchmarking rules does the tax authority apply?

The interquartile range is the test, in force since 1 November 2024. Where a result falls outside it, the tax authority adjusts to the median rather than to the nearest quartile, which is the expensive end of the range.

There is no stated preference between domestic and foreign comparables and no annual refresh requirement for benchmarking studies. The self-adjustment route is the part worth planning around: it lets a taxpayer correct its prices before an audit, which changes when the study should be finished relative to the 30 June deadline rather than after it.

What are the penalties for getting Chile transfer pricing wrong?

Two separate charges, and one of them is avoidable. A late, missing, incomplete or wrong sworn statement draws 10 to 50 annual tax units. A price adjustment draws a further 5% of the adjustment difference, and that one is waived if the sworn statements and the requested documents were delivered on time.

The waiver on the 5% fine is the practical reason to file on time even when you expect an adjustment. Filing late costs twice: the sworn statement fine, and then the adjustment fine you could have had waived.

Can you get an advance pricing agreement in Chile?

Yes, unilateral and bilateral. An agreement covers the year it is signed plus the four following commercial years, with rollback of up to three prior years, and renewals of up to five years. The tax authority answers a pre-filing request within two months and decides within 12 months, and silence counts as a rejection^[8] rather than an approval.

Multilateral availability is not confirmed from a primary source, so this page does not assert it. The tax authority may sign agreements with other administrations, which is what makes the bilateral route workable for a foreign parent.

What is a foreign parent exposed to in Chile?

More than it expects, because the group level thresholds reach a parent that is nowhere near Chile. The EUR 750,000,000 consolidated revenue test pulls in the Chilean master file and the country-by-country obligations through the designated entity and delegation notice mechanics, even when the parent sits abroad.

Underneath that, the Chilean subsidiary's own CLP 200,000,000 and CLP 500,000,000 transaction tests pull routine intercompany flows into the local file and Form 1907. Two clocks belong on the parent's calendar: 30 June 2026 for the four returns, and the 30 calendar days before the country-by-country deadline for any delegation notice.

How we help with Chile transfer pricing

Chile gives you one date and four returns, and the sworn statement format means a late file is a fine rather than a request for more time. We scope each entity against the three local file tests, build the benchmarking to the interquartile standard, prepare all four returns and surface the delegation notice window before it closes. See how our transfer pricing software works.

Book a demo to get your Chilean filing calendar mapped before 30 June 2026.