Under Article 63 of the Chilean Tax Code, the Chilean Internal Revenue Service (SII, for its initials in Spanish) is entitled to verify the accuracy of tax returns and request any information and supporting documentation necessary to carry out that review. 

To achieve this, the SII may issue a formal citation requiring the taxpayer to provide information. In response, the taxpayer may rectify, clarify, expand, or confirm the information contained in the filing. 

The general deadline to give an answer is one month from the date the citation is notified. However, if additional time is needed, the taxpayer may request an extension by submitting a written application to the SII office that issued the citation. The responsible SII official may grant a single extension of up to one additional month. 

The citation process is one of the SII’s principal review tools, allowing tax authority to gather information, clarify discrepancies, and judge whether adjustments to a taxpayer’s tax position may be justified before taking further actions, such as issuing liquidation or tax collection notices. 

The most common tax review citations issued by the SII involve: 

• Discrepancies identified during the Annual Income Tax filing process (Operación Renta, in Spanish). 

• Inconsistencies between affidavit and information reported in Forms 22 or 29. 

• VAT (IVA, for its initials in Spanish) differences or discrepancies. 

• Requests related to tax refunds, including temporary monthly tax payments (PPM, for its initials in Spanish). 

First steps after receiving a tax review citation 

A tax review citation typically specifies: 

• The matter or issue under review. 

• The tax periods involved. 

• The supporting information or documents required. 

• The taxes being reviewed by the SII. 

To prepare an effective response, taxpayers should gather all relevant supporting documentation. Commonly requested records include: 

• Financial statements, general financial records, and supporting accounting records. 

• Tax calculations and determinations, including Taxable Net Income (RLI, for its initials in Spanish), Taxable Equity (CPT, for its initials in Spanish), and Business Income Tax Records (RRE, for its initials in Spanish). 

• Bank statements and proof of payments or transfers. 

• Documentation that supports reported expenses, income, investments, or tax credits. 

• Invoices, receipts, and other tax documents supporting the transactions under review. 

• Contracts related to the questioned transactions, such as purchase and sale agreements, service contracts, loan agreements, or lease agreements. 

In most cases, supporting information and documentation must be submitted through the SII Electronic Tax File System (Expediente Electrónico, in Spanish) using the taxpayer’s Tax Identification Number (RUT, for its initials in Spanish) and password, or their national digital identity credentials (Clave Única, in Spanish). The documentation must be uploaded to the specific electronic file identified in the tax review citation or information request. 

If the SII establishes that the taxpayer’s response is incomplete or insufficient, it may request additional explanations, clarifications, or supporting documentation. In such cases, the taxpayer will generally be granted a further one-month period to provide the requested information. 

When to seek professional advice 

Whether professional advice is needed will depend on the complexity of the issues raised by the SII and the amounts involved. 

There are two broad categories of tax review citation can be identified. The first includes cases where it is apparent that the SII has made an error when issuing the citation, whether due to mismatching information, duplicate records, or issues resulting from large-scale review programs. The second includes cases where the citation results from a more detailed review of the taxpayers’ affairs. In both situations, responding within the corresponding deadline is essential to clarify the issues identified by the SII and reduce the risk of progressing to a tax liquidation or a tax collection notice. 

What happens if the taxpayer doesn´t respond? 

If no response is submitted within the pertinent deadline, the SII may issue a tax liquidation or a tax collection notice, establishing the taxes owed based on the information and records available to the tax authority. 

Once the liquidation or collection letter has been notified, the taxpayer may file a Voluntary Administrative Reconsideration Request (RAV, for its initials in Spanish) challenging the liquidation, within 30 business days from notification. 

It´s important to note that a tax review citation does not equal a penalty or sanction. To be precise, it is an opportunity for the taxpayer to provide supporting documentation and explain their position before the SII reaches a final decision as part of the review process. 

For this reason, responding on time and providing a complete submission is essential. For further information or assistance regarding this matter, please contact the Unitax team.