By Claudio Escobar, Senior Tax Manager at CCL Auditores Consultores
Chile has taken a significant step by placing fiscal governance at the center of the tax conversation. The question is no longer whether this innovation was necessary, but whether the system will be able to turn it into a real, credible, and useful practice for a broad range of taxpayers.
Tax sustainability has moved beyond being an attractive concept at a rhetorical level to becoming a substantive regulatory signal. With the incorporation of Article 8 No. 18 into the Tax Code, through Law No. 21,713 on Tax Compliance, and its subsequent development by the Chilean Internal Revenue Service (SII), a rather uncommon discussion has emerged in Chile: that compliance should not be measured solely by the formal accuracy of filings or the intensity of audits, but also by the quality of governance underpinning tax decisions.
This shift deserves recognition. In a system where the relationship between taxpayers and the tax authority is often framed in terms of review, contingency, or dispute, introducing a logic that values transparency, internal controls, and cooperation represents a different institutional signal. It does not, by itself, solve the system’s challenges, but it does help move the conversation toward more mature standards, aligned with a culture of compliance that is less reactive and more strategic.
During 2025, the SII also made progress in operationalizing this model. Circular No. 6 established the interpretative framework, while Exempt Resolutions No. 70, 71, and 72 completed the structure by regulating the registry of independent certifiers, the annual certification process, and cooperation agreements with business groups. The novelty, therefore, is no longer limited to the law: there are now concrete procedures, requirements, and effects.
This progress is also relevant for another reason: it takes tax management out of a purely technical space and places it where it arguably always belonged—within boardroom discussions, risk management, and organizational control structures. A company seeking certification under this standard must do more than comply; it must demonstrate policies, traceability, defined responsibilities, and oversight consistent with the strategic importance of tax matters.
That said, a sound regulatory direction does not eliminate fundamental questions. Implementation remains at an early and gradual stage, and is more visible among sophisticated organizations than in the broader market. This is not surprising: governance requirements, risk matrices, and control documentation align more naturally with large corporate groups than with mid-sized taxpayers or less institutionalized structures.
This does not undermine the regulation, but it does require a realistic view of its future. Tax sustainability could become one of the most valuable innovations in the Chilean system, but only if it proves that it will not be a standard reserved for those who already have sufficient resources, advisory support, and corporate maturity.
Its success will not depend on the novelty of the concept, but on its ability to translate into trust, predictability, and better practices for a broader universe. Otherwise, the risk is clear: it may become a valuable but peripheral credential—appreciated in discourse, yet limited in real impact. That is the real test: ensuring that this regulation does not remain a sophisticated promise, but instead produces a meaningful change in how tax compliance is understood.