Practice area

World TP Reviews

Transfer pricing

BaseFirma Chile’s transfer pricing practice focuses on advising multinational companies on doing business in the country. Its work is broad and includes advising companies on three-tier documentation, planning and transfer pricing policy implementation, audit defense and assets valuation. Working in tandem with its global network, the firm’s Chile practice provides high-value services of coordination regarding global and regional transfer pricing documentation.

Over the last year, its experience was exhibited by its involvement in implementing a transfer pricing cash pool policy, which evaluated the feasibility of customising the group’s European cash pool policy, but also included international tax advice regarding the deductibility.


The Deloitte tax and transfer pricing practice is led by Pablo Albertini, an attorney with more than 31 years of experience advising clients on all matters of taxation. The team led by Albertini is mostly focused on audit defence, tax planning, business model optimisation and APAs, among other things. 

The firm’s global transfer pricing network helps companies manage risks by assisting with documentation in order to resolve disputes effectively.

A key member of the team is partner Alejandro Paredes, who has more than 11 years of experience in transfer pricing matters. Paredes has assisted clients with transfer pricing analysis, planning and defence. Vanesa Lanciotti is the transfer pricing manager at the firm. She specialises in intercompany financial transactions and commodities.


KPMG’s transfer pricing practice is one of the oldest specialised transfer pricing practices in the country and focuses its attention on documentation, planning, transfer pricing dispute resolution and APAs. The team is involved with major multinationals with a particular emphasis on the energy, mining, utilities, banking and financial institutions, as well as large retailers and major electronic goods distributors.

The team also has considerable experience with transfer pricing audits, with all of the 20 companies that it advised on such matters receiving favourable decisions by the Chilean tax authorities.

The team recently added Gloria Mardonez and Luis Seguel as tax and legal partners.


PwC Chile maintains a dominant presence in Chile, with more than 41 individuals dedicated to providing transfer pricing-related services. Roberto Carlos Rivas leads the team. It is one of the only firms to have an internal group of lawyers specialised in transfer pricing controversy resolution and litigation.

Over the past year, its transfer pricing team expanded with the help of one transfer pricing professional of one of the largest digital industrial companies in the world. Under this alliance, PwC’s transfer pricing team will help to strengthen the company’s transfer pricing capabilities moving forward.

It has also successfully defended clients before the Chilean revenues service at different stages of transfer pricing audits and litigation.