The deadlines for filing formal transfer pricing duties begin during the month of September

The deadlines for the presentation of the formal transfer pricing duties, specifically the informative declaration and the initial local report on September 7 of the current year, according to the last number of the NIT, as follows:

Last digit of NIT

Expiration Date

1

September 7

2

September 8

3

September 9

4

September 12

5

September 13

6

September 14

7

September 15

8

September 16

9

September 19

0

September 20

Who is subject to the transfer pricing regime?

All those taxpayers of income tax and its complementary taxes who have registered operations with:

  • Foreign economic affiliates; or
  • Local economic related parties located in free trade zones; or
  • Entities located in non-cooperative jurisdictions of low or no taxation.

Criteria to determine if you are obliged to prepare and file the informative declaration and/or the transfer pricing supporting documentation

The criteria for the determination of the formal transfer pricing obligations are established in articles 260-5 and 260-9 of the Colombian Tax Statute, and are as follows:

  1. Transfer Pricing Information Statement:

In accordance with the provisions of Article 260-9 of the ET. Those Colombian taxpayers that have registered operations subject to the transfer pricing regime and that comply with any of the following criteria shall be obliged to prepare and file the informative return:

Concept

Stope UVT*

Stope 2021

Gross Equity; or

100.000

3.630.800.000

Gross Income; or

61.000

2.214.788.000

Transactions with Entities (related or not) located in non-cooperative jurisdictions of low or no taxation or preferential regimes (TBI), regardless of the amount.

 * Tax Value Units (2021: 36,308)

  1. Proof of transfer pricing documentation.

In accordance with the provisions of article 260-5 of the ET, the transfer pricing supporting documentation is composed of the local report and the transfer pricing master report.

All those taxpayers that are obliged to prepare and file the transfer pricing information return must prepare a local report including the required analyses to validate compliance with the arm's length principle in relation to the following types of operations:

Concept

Stop UVT*

Stop 2021

Accumulated amount by type of operation (economic affiliates)

45.000

1.633.860.000

Accumulated amount by type of transaction (TBI)

10.000

363.080.000

 

On the other hand, all taxpayers that are required to prepare and file the local transfer pricing report and are part of a Multinational Group must file the master transfer pricing report.

Document

Boletin-Informativo_​Vencimientos-de-Precios-de-Transferencia-2021ENG.pdf

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