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COUNTRY BY COUNTRY REPORT OBLIGATIONS COULD BE DUE EVEN IF NO TRANSFER PRICING DOCUMENTATIONS MUST BE FILED

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COUNTRY BY COUNTRY REPORT OBLIGATIONS COULD BE DUE EVEN IF NO TRANSFER PRICING DOCUMENTATIONS MUST BE FILED

International Taxation

Transfer pricing obligations are due as of the 11th of September and a Country by Country report notification could be due even if the taxpayer is not required to file Informative Transfer Pricing Return and Transfer Pricing Documentation

 

The Country by Country report contains information regarding global allocation of income of a Multinational Enterprise (“MNE”), paid taxes and some indicators of the activity of the MNE from a global perspective. The Colombian entity that is part of a MNE should inform DIAN if it is the ultimate parent company of the MNE or if it was designated by the parent company to file the report.

Pursuant to Resolution No. 0000040 of 2018, a notification to DIAN should be filed if the Colombian entity is not the ultimate parent company or was not designated to file the report. If the Colombian entity is obliged to file Informative Transfer Pricing Return the notification is made by filing sections 39 to 45 of the Return. If the Colombian entity is not due to file Informative Transfer Pricing Return the notification should be made using the form prepared by DIAN and sent via email to preciostransferencia@dian.gov.co with the subject “Notificación – Informe País por País”.

In both cases the deadline to send the notification is the same as the deadline for submitting the Informative Transfer Pricing Return and Transfer Pricing Documentation.