The Chilean Internal Revenue Service has updated the instructions governing the voluntary administrative reconsideration process through Circular No. 26, introducing changes that directly affect how companies manage tax disputes.

While it may appear to be a technical update, this adjustment redefines the role of administrative reconsideration within the broader process. The update aligns with recent regulatory developments and replaces prior administrative criteria, impacting both how responses are structured and how arguments are developed and supported.

In practice, when the procedure changes, the strategy changes as well. Elements such as timing, evidence, and the potential escalation of a dispute are no longer separate considerations, but part of an integrated approach from the outset.

Administrative reconsideration should no longer be viewed merely as a preliminary step, but rather as a strategic tool within tax dispute management. This shift requires earlier and more structured analysis, as well as stronger internal coordination.

For companies exposed to tax audits or disputes, it is particularly important to review ongoing matters, update internal response protocols, and ensure proper alignment between legal, tax, and finance teams.

A timely and strategic approach can make a meaningful difference in the outcome of the process and help mitigate future risks and costs.