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Colombia Issues Resolutions on Transfer Pricing Documentation

Jessica Silbering-Meyer  

Jessica Silbering-Meyer  

On May 22, 2019, Colombia issued Resolution 34 of 2019 on submitting the Informative Transfer Pricing Statement – Form 120 corresponding to the 2018 tax year and part of the 2019 tax year, as well as the country-by-country (CbC) reporting notification. This resolution applies to those who are required to electronically submit Form 120 through the Special Administrative Unit of the National Tax and Customs Administration (DIAN).

According to article 260-9 of the Taxation Statute, taxpayers engaged in related-party transactions, and whose gross assets on the last day of the taxable year are at least 100,000 TVU or whose gross income of the relevant year is at least 61,000 TVU must submit an annual informative income tax return.

The member entity of a multinational group that is tax resident in Colombia will notify the DIAN if it is the parent, controlling, or substitute entity. If the entity is not the parent, controlling, or substitute entity, it must notify the DIAN of the reporting entity’s identity and fiscal residence.

Also on May 22, 2019, Colombia issued Resolution 33 of 2019, which applies to taxpayers required to prepare and electronically submit master and local files through the DIAN for the 2018 tax year and part of the 2019 tax year. See article 260-5 of the Taxation Statute.

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