The Chilean Internal Revenue Service has implemented a 24 question disclosure based on BEPS, although going farther than the OECD’s Actions. EY’s Global Tax Alert is provided for reference:
- Percentage of related party revenues
- EBITDA percentage of related party expenses
- Foreign related parties with no staff or relevant assets, and identify those which participated in intercompany transactions
- Corporate reorganizations, transfer of functions involving foreign companies.
Taxpayers listed in the Large Business Division (Grande Contribuyente) must file SS No. 1913, as well as those considered large companies by the Chilean IRS. SS No. 1913 must be filed annually from 2016 onwards before filing the corporate return (Form 22), which is due in April.
A careful reading of the new disclosures should be undertaken by those having Chilean operations; this is also a trend that will probably develop in other countries.