Background
Last month, taxpayers responsible for preparing monthly VAT returns encountered an unexpected situation: the Purchase and Sales Ledger (Registro de Compras y Ventas – RCV) already contained Import Declarations (Declaraciones de Ingreso – DIN) that had not been entered by the taxpayer, some import documents were missing from the ledger, and difficulties were reported when attempting to manually upload the missing DINs. What initially raised concerns among taxpayers is, in fact, a new automation process implemented by the Chilean Internal Revenue Service (SII).
The SII continues to strengthen its cross-checking strategy between VAT and income tax by updating the Purchase and Sales Ledger of taxpayers engaged in foreign trade operations. Since June 2026, the SII has been automatically incorporating Import Declarations reported by the Chilean Customs Service, replacing the manual registration process previously performed by taxpayers.
This measure forms part of the 2026 Tax Compliance Management Plan and the SII’s broader strategy to combat VAT fraud and evasion. It also responds to a significant volume of transactions: during 2025, a total of 221,867 VAT returns (Form 29) reported import VAT credits through codes 535 and/or 553, a process that until now depended entirely on the consistency between taxpayer declarations and Customs information.
Far from being a neutral simplification, this change reinforces the controls that taxpayers were already required to perform. Information reported by Customs does not always coincide with the tax criteria that determine the correct period in which VAT credits may be claimed. As a result, taxpayers may face increased audit exposure.
A. What Changes in the Purchase and Sales Ledger?
The SII now automatically uploads Customs-reported DINs into the taxpayer’s purchase ledger. If a declaration has not been reported by Customs, it will not appear in the RCV.
The information incorporated automatically includes:
- DIN identification number (folio)
- Acceptance date
- Net amount
- Recoverable VAT amount
- Total amount
Fields such as purchase type, supplier tax identification number (RUT), and receipt date are determined directly by the SII.
While fields such as folio number, issue date, amounts, and non-creditable tax remain editable by taxpayers for the time being, the SII has already announced that future system updates will block these modifications. Corrections will then only be possible by deleting and re-entering the document.
DINs previously uploaded manually by taxpayers will be replaced by the automated process, preserving both the folio number and reporting period. Duplicate folio numbers within the same reporting period will not be accepted.
B. VAT Credit Claim Period
The area of greatest risk for taxpayers lies in the timing criteria applied by the new system.
According to the SII’s technical documentation, DINs are uploaded into the RCV based on their acceptance date rather than the date on which the tax was actually paid.
The SII justifies this approach by noting that 99.67% of DINs are paid within the same reporting period in which they are accepted. However, the remaining 0.33%—which is not insignificant in absolute terms—present situations where the acceptance date and payment date fall in different tax periods.
This distinction is important because the right to claim VAT input tax on imports arises upon the actual payment of the tax, not upon acceptance of the declaration.
If the RCV automatically records a DIN in the acceptance period and that period differs from the payment period, taxpayers may inadvertently claim VAT credits in the wrong reporting period, exposing themselves to audit findings, credit disallowances, or required amendments to their VAT return.
The SII expressly acknowledges this limitation. If a DIN is recorded in a different period from the one in which the tax was paid, the taxpayer must manually remove the declaration from the incorrect period and re-enter it in the appropriate one.
The system does not perform this correction automatically. Furthermore, the proposed VAT return (Form 29) is generated based on all information contained in the purchase ledger at the time of filing. Consequently, any undetected timing error may flow directly into the VAT return and become subject to future review.
C. Recoverable Credit: VAT Only
Taxpayers should bear in mind that the VAT amount reflected in the DIN information uploaded to the RCV corresponds exclusively to recoverable VAT, provided the requirements of Article 23 of the VAT Law are met.
This amount does not necessarily match the total amount paid to the Chilean Treasury (Tesorería General de la República – TGR).
Payments made to the Treasury often include additional charges, such as customs duties (ad valorem duties) and other customs-related levies, which do not qualify as recoverable VAT input tax.
Recommended Actions
In light of these changes, we recommend that taxpayers incorporate the following controls into their monthly VAT closing procedures:
- Reconcile each DIN individually, comparing the acceptance date automatically recorded by the SII with the actual tax payment date, and adjust the reporting period whenever discrepancies exist.
- Verify that the VAT credit claimed corresponds exclusively to recoverable VAT, excluding customs duties and other charges included in the total amount paid under the DIN.
- Regularly review updates made to the Purchase and Sales Ledger and make corrections where necessary while the system continues to evolve.
This update confirms that information sharing and cross-checking between Customs and the SII will continue to deepen. We recommend incorporating these validations as a permanent component of monthly VAT compliance procedures and remain available to assist in reviewing any specific situations arising from this new system implementation.