Chile has been a member of the OECD since January 2010 and, as such, it has slowly been making the corresponding changes in order to adapt its legislation to OECD’s guidelines, including what it says in relation to Transfer Pricing. Within this matter, arm’s length is the fundamental principle that companies must respect in their operations. The aim is for each country to tax what is fair and reasonable in relation to the commercial transactions performed between cross-border related companies and in relation with those performed with companies located in tax havens, regardless in the latter if there is a relationship between the companies, with some exceptions which the Income Tax Law establishes.
TECHNICAL TRANSFER PRICING STUDIES
Preparation of the technical study of Transfer Price according to the guidelines issued by the OECD; search for comparables in Osiris international database.
PROCESSING OF ADVANCE AGREEMENTS
Representation of the taxpayer before the Internal Revenue Service in order to make an advance agreement (APA), for the period allowed by law.
APPLYING OF AGREEMENTS TO AVOID DOUBLE TAXATION.
Analyze in the different international transactions the application of the Agreement to Avoid the International Double Taxation, respectively, and the consequent qualification of the operation carried out, by the taxpayer, in the specific articles.