Alerta Legal 004-2020 Chile: Nueva Declaración Jurada Anual “Archivo Maestro” (Formulario N°1950) y “Archivo Local” (Formulario 1951), incorporados mediante la Resolución Exenta SII N°101 del 31 de agosto del 2020.

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  1. Antecedentes:

El 27 de diciembre del año 2016, el SII publicó la Resolución Exenta N° 126 en la que contempla lo dispuesto en la Resolución Exenta N° 14 de 2013 que establece la obligación de presentar Declaración Jurada Anual informativa de Precios de Transferencia y además establece obligación de presentar la Declaración Jurada Anual denominada “Reporte País por País” a contribuyentes que cuentan con filiales en el extranjero.

Ahora, con fecha 31 de agosto del año 2020, el SII publico la Resolución Exenta N° 101 (en adelante “La Resolución”) donde se estable la obligación de presentar las Declaraciones Juradas Anuales Informativas de Precios de Transferencia denominadas “Archivo Maestro y “Archivo Local; así mismo se modifica la Resolución Exenta N° 126, del 2016.

Dicha incorporación, tiene como finalidad adoptar un enfoque estandarizado respecto de la documentación de Precios de Transferencia, conforme a lo establecido en la Acción13 de Plan de Acción contra la Erosión de la Base Imponible y el Traslado de Beneficios, conocido por sus siglas en inglés BEPS (Base Erosion and Profit Shifting).

2. Obligados a la Declaración Jurada Anual Archivo Maestro

Esta nueva declaración, la cual tiene vigencia a partir del año tributario 2021 (año comercial 2020), deberá ser presentada por los siguientes contribuyentes:

A. La  entidad  matriz  o  controladora  del  Grupo  de  Empresas  Multinacional (en  adelante también “GEM”),que tenga residencia en Chile para los efectos tributarios, en la medida que los  ingresos  del  conjunto  de  entidades  que  formen  parte  de  dicho  grupo en  Chile  y  en  el exterior, al 31 de diciembre del año que se informa, sea al menos, de setecientos cincuenta millones  de  euros(€750.000.000.-) al  momento  del  cierre  de  los  estados  financieros consolidados, según el tipo de cambio observado al 1 de enero de 2015, determinado por el Banco Central de Chile conforme al N°6 del Capítulo I del Compendio de Normas de Cambios Internacionales; o bien,

B. La entidad que integra o pertenece al GEM, que tenga residencia en Chile para los efectos tributarios, y que haya sido designada por la entidad matriz o controladora de dicho grupo como la única sustituta de esta para efectos de presentar la Declaración Jurada “Reporte País por País” en su país de residencia tributaria, a nombre de la entidad matriz o controladora.

3. Obligados a la Declaración Jurada Anual Archivo Local

Esta nueva declaración, la cual tiene vigencia a partir del año tributario 2021 (año comercial 2020), deberá ser presentada por los siguientes contribuyentes:

A. Pertenezcan al segmento de Grandes Empresas; de acuerdo a los criterios establecidos en la Resolución Exenta SII N° 76 del 23 de agosto de 2017,

B. Su entidad matriz o controladora del GEM haya debido presentar el Reporte País por País ante el Servicio de Impuestos Internos u otra Administración Tributaria para el año tributario respectivo; y,

C. Que en dicho año hayan realizado una o más operaciones con partes relacionadas que no tengan domicilio o residencia en Chile, de acuerdo con las normas establecidas en el artículo 41 E de la Ley sobre Impuesto a la Renta, por montos superiores a $200.000.000 (doscientos millones  de  pesos  chilenos)o  su  equivalente  de  acuerdo  a  la  paridad  cambiaria  entre  la moneda nacional y la moneda extranjera en que se realizaron dichas operaciones, vigente al 31 de Diciembre del ejercicio que se informa, de acuerdo a publicación efectuada por el Banco Central de Chile

4. Contenido de la Declaración Jurada Anual Archivo Maestro y Archivo Local

4.1. Declaración Jurada Anual Archivo Maestro

Los contribuyentes obligados a la Declaración Jurada Anual Archivo Maestro, deberán presentar al SII el Formulario N° 1950, denominado “Declaración Jurada Anual Archivo Maestro”, según el formato e instrucciones indicados en los Anexos N.º 1 y 2. (Ver Anexo 1 de la presente Alerta).

Adicionalmente, se deberá presentar un Anexo al Formulario N° 1950, referente a la Información Descriptiva de la declaración Jurada Anual Archivo Maestro (Anexo N°3 de La Resolución), y todos los documentos indicados en dichos anexos, y de acuerdo a las definiciones del Anexo N.º 7 de La Resolución. Conforme se detallan a continuación:

A. Información Descriptiva. La información solicitada en este apartado, tiene como objeto entregar una visión general de las actividades Grupo de Empresas Multinacional, tales como:

  • Sección 1: Información sobre las actividades del Grupo de Empresas Multinacional. Donde se detalla información sobre las principales actividades económicas del grupo, cadena de suministros, principales mercados geográficos, análisis funcional por cada entidad del Grupo de Empresas Multinacional y operaciones de reorganización empresarial.
  • Sección 2: Activos Intangibles del Grupo de Empresas Multinacional. Estrategias globales, políticas de precios de transferencia y transferencias relevantes de derechos sobre activos intangibles en el GEM.
  • Sección 3: Actividades Financieras del Grupo de Empresas Multinacional. Descripción de las fuentes de financiamiento, financiación centralizada, políticas de Precios de Transferencia.

B. Documentación que se debe presentar. Adicionalmente a la información solicitada en el apartado anterior, el contribuyente deberá presentar los siguientes documentos a través del expediente electrónico habilitado:

  1. Malla Societaria del Grupo.
  2. Copia de los acuerdos entre partes relacionadas del GEM.
  3. Copia de los Acuerdos de Precios Anticipados.
  4. Copia de cualquier otra decisión emitida por una autoridad fiscal relativa a la distribución de los beneficios del grupo entre países.
  5. Estados Financieros Anuales Consolidados del GEM.
  6. Políticas de Precios de Transferencia del GEM

4.2. Declaración Jurada Anual Archivo Local

Los contribuyentes obligados a la Declaración Jurada Anual Archivo Local, deberán presentar al SII el formulario N°1951, denominada “Declaración Jurada Anual Archivo Local”, según el formato e instrucciones indicados en los Anexos N.º 4 y 5 de La Resolución. (Ver Anexo 2 de la presente Alerta).

Adicionalmente, estos contribuyentes deberán presentar el Anexo al Formulario N.º 1951 sobre la Información Descriptiva de la declaración Jurada Anual Archivo Local (Anexo N.º 6 de La Resolución), y todos los documentos indicados en dichos anexos, y de acuerdo a las definiciones del Anexo N.º 7 de La Resolución. Conforme se detallan a continuación:

A. Información Descriptiva. La información solicitada en este apartado, tiene como objeto entregar una visión más detallada de las operaciones efectuadas por el contribuyente con partes relacionadas del exterior, tales como:

  • Sección 1: Información sobre la Entidad Local. Donde se detalla la actividad de la compañía, las estrategias del negocio, principales competidores, la descripción de las operaciones de reorganización empresarial, así como de transmisión de intangibles que se hayan producido durante el período informado.
  • Sección 2: Análisis sobre Operaciones Vinculadas. Descripción del análisis funcional de contribuyente y las partes relacionadas del exterior; así como especificar si han existido cambios en el análisis de comparabilidad respecto al año anterior, como por ejemplo del método de Precios de Transferencia utilizado. Así mismo, se deberá completar la tabla del análisis de comparabilidad realizado por tipo de operación informada, conforme se detalla en el anexo 3 de la presente alerta.
  • Sección 3: Información Financiera de la Entidad Local. La información contenida en esta Sección, deberá ser presentada a través de un archivo en formato “.xls” o “.xlsx”. Así mismo, en caso el análisis de Precios de Transferencia de las operaciones vinculadas se realizó con información financiera segmentada, se deberá completar la tabla indicada en el anexo 4 de la presente alerta.

4.2. Documentación que se debe presentar. Adicionalmente a la información solicitada en el apartado anterior, el contribuyente deberá presentar los siguientes documentos a través del expediente electrónico habilitado:

  • Estructura organizacional.
  • Copia de los acuerdos entre la entidad local y sus partes relacionadas.
  • En caso de operación de crédito u operación financiera, se deberá aportar la tabla de amortización.
  • Copia de los Acuerdos de Precios Anticipados.
  • Copia de cualquier otra decisión emitida por una autoridad fiscal, en las que no fue parte el Servicio de Impuestos Internos y que están relacionados con las operaciones vinculadas informadas en la Declaración Jurada Anual Archivo Local.
  • Estados Financieros Anuales Individual de la Entidad Local.
  • Conciliación de la Información Financiera de la Entidad Local.
  • Información Financiera de los Comparables utilizados.

5. Forma de presentación

Los contribuyentes deberán presentar ambas declaraciones por internet, a través de la opción de Declaraciones Juradas de Renta, disponible en el sitio web del SII, www.sii.cl. Conjuntamente, con los anexos y documentación de ambas declaraciones.

6.    Fecha y vigencia de Presentación de la Declaración Jurada Anual Archivo Maestro y Archivo Local

El plazo para presentar las referidas declaraciones juradas anuales y sus anexos, vencerá el último día hábil del mes de junio de cada año, respecto de las operaciones llevadas a cabo durante el año comercial inmediatamente anterior, plazo que podrá ser prorrogado por una sola vez, hasta por tres meses.

La obligación de ambas declaraciones regirá respecto de las operaciones efectuadas en ejercicio comercial 2020 a presentarse en el año tributario 2021.

7. Sanciones

El incumplimiento de ambas declaraciones se sancionará conforme al N° 6 del artículo 41 E de la Ley sobre Impuesto a la Renta.

Cabe indicar que, de acuerdo con lo dispuesto en la parte final del inciso tercero del artículo 8 N°16 del Código Tributario, en caso los documentos o escritos acompañados en ambas declaraciones se encuentren en blanco, sin las menciones necesarias, o no sean los exigidos por las normas legales, se tendrán por no presentados, sin perjuicio de las sanciones que procedan por incumplir las referidas normas legales.

8. Modificaciones de la Resolución Extensa N°126 del 2016

Se modifica los siguientes puntos de la Resolución Extensa N° 126 del 2016:

  • En su considerando N° 17, reemplazando sus párrafos primero y segundo.
  • En su resolutivo N°2, letra B), parte final, donde se elimina la frase “El Formulario 1937 se entenderá formando parte de la declaración jurada contenida en el Formulario N° 1907”; y,
  • En su resolutivo N°4, eliminándose el segundo párrafo.

Cabe precisar que, la presente Resolución modifica la Resolución Extensa N°126 del 2016, mas no la elimina; Por consiguiente, se mantiene la Declaración Jurada Anual Informativa de Precios de Transferencia (Formulario 1907).

9. Conclusiones y recomendaciones:

  • Estas nuevas declaraciones tienen por propósito obtener mayor información cualitativa y cuantitativa para caracterizar a los grandes contribuyentes, en el marco de la gestión de cumplimiento tributario.
  • Se puede inferir que la información solicitada, en las nuevas declaraciones, será una herramienta muy útil para el SII en fiscalizaciones futuras.
  • Los contribuyentes deben contar con una asesoría especializada tanto legal como técnica a fin de cumplir con la presentación de las correspondientes declaraciones, pues las mismas realizan una serie requerimientos que tienen relación con la toma de decisiones de negocio de la empresa en Chile, para definir si las mismas corresponde a acciones empresariales autónomas (Precios de Transferencia).
  • Se recomienda realizar la elaboración de ambas declaraciones y los anexos complementarios con anticipación, a fin de poder analizar las operaciones con partes relacionadas del exterior y verificar el cumplimiento de las normas de valor de mercado y en caso de cualquier ajuste, están puedan informarse anticipadamente en la Declaración de Impuesto a la Renta (Formulario 22).

Para cualquier consulta en Chile sirva comunicarse con Rodrigo Serrano, sus datos de contacto se mencionan a continuación:

TP Consulting Chile

e-mail: rserrano@tpconsulting-group.com

Tel: (56-2) 2944-5015

Alonso de Córdova 5870, Oficina 1605, Los Condes, CHILE.

Anexo 1: Formato de declaración Jurada anual Archivo Maestro (Formulario 1950)

Anexo 2: Formato de declaración Jurada anual Archivo Local (Formulario 1951)

Anexo 3: Detalle del análisis comparabilidad

Anexo 4: Tabla sobre la Información Financiera Segmentada de la Entidad Local

Alertas de precios de transferencia

Eventos

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