Transactions subject to the transfer pricing regime are those that take place between income taxpayers and their related parties abroad or local parties who benefit from the free trade zones regime.

Income taxpayers obliged to fulfil transfer pricing requirements are those that perform transactions with related parties located abroad that at year-end exceed the following established caps:
 

Those taxpayers that comply with the previously mentioned caps will be obliged to file the Informative Return that will contain the information related to the totality of operations carried out with related parties abroad and/or related parties located in free trade zones and/or persons, corporations, entities or companies located, resident or domiciled in non-cooperating jurisdictions, low or no taxation and preferential tax regimes. 

In turn, those taxpayers with transactions that exceed the accumulated amount of COP$ 1,633,860,000, by type of operation during the taxable year under review, are required to submit the Support Documentation

The Colombian tax authority has issued a press release on Decree No. 1778 of December 20th, 2021, which sets out the deadlines for tax return (declaration) filing and payment in 2022, as well as transfer pricing documentation deadlines, including Local/Master file and Country-by-Country (CbC) reports, and other tax filing obligations.

Some of the main deadlines for companies, which depend on the last digits of the taxpayer's tax number (NIT), are as follows:

Information Return and Local File
 

Master File

Country – by – country Report

Those companies that are not required to submit the Transfer Pricing Regime Information Return, must comply with the Country-by-Country Information Notification to the Tax Authority (DIAN) via email to the mailbox preciostransferencia@dian.gov.co, identifying the subject as: "Notification - Country by Country Report" on the same dates established in Decree 1778.

Our group of professionals specialized in this matter is available to answer your questions regarding this matter, please contact us at: fzambrano@bu.com.co