This Resolution issued by the Internal Revenue Service (SII) in March 2025 is based on Art. 41 H of the Income Tax Law, which establishes when a territory or jurisdiction is considered to have a preferential tax regime, determining that the SII will rule, through a resolution, on those territories or jurisdictions that qualify as such.
The aforementioned Resolution establishes, in its Annex, the list of territories or jurisdictions that are considered to have a preferential tax regime, which will be applicable for tax purposes starting on January 1, 2025.
Transactions carried out with entities located in any territory or jurisdiction mentioned in this Annex must be reported for Transfer Pricing purposes.
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