SII Files 9 Anti-Avoidance Cases, Total Fiscal Impact Nears $19.7 Billion

• SII has presented 9 requests to TTA under the General Anti-Avoidance Rule with a fiscal impact of approximately $19.7 billion.
• Main risks addressed include asset dilutions, loss generation increasing PPUA refunds, and schemes to defer tax obligations on passive income from foreign entities.
• Since 2021, 63 requests have been submitted, addressing common risks like asset dilutions and business reorganizations to avoid higher values.
• Total fiscal impact of all requests exceeds $128 billion.
• The Santiago Oriente Regional Directorate leads with 34 cases totaling over $82 billion, followed by Santiago Sur with 6 cases and Valparaíso with 5 cases.
• In the first quarter of this year, 9 requests focused on asset dilution and loss generation, with a fiscal impact of about $19.7 billion.
• Asset dilutions affecting income or donation tax lead with 33 cases, followed by reorganizations and loss generation increasing PPUA refunds with 5 cases each.
• Fewer cases address risks like profit shifting to low-tax jurisdictions, financing structures to avoid profit recognition, and service provision through shared entities.
• Taxes involved are mainly income and donation taxes.
• Of the cases leading to TTA requests, 34 originated from Santiago Oriente, 6 from Santiago Sur, and 5 from Valparaíso.
• The 9 requests in the first quarter of 2025 originated from audits targeting Chilean residents with foreign entities.

Source: sii.cl

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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