Chile Issues Ruling on Determining Arm's Length Price of Intangibles

The Chilean tax authority (Servicio de Impuestos Internos - SII) has published Letter Ruling No. 1801 of 20 July 2026, which addresses a taxpayer question on whether the DEMPE analysis as detailed in Chapter VI of the OECD's Transfer Pricing Guidelines can be used to determine the normal market value (arm's length price) of intangibles in accordance with Article 64 of the Tax Code. The second paragraph of Article 64 provides that normal market values are understood as those that would have be…