It is not feasible to adjust transfer pricing studies as a result of the changes under IFRS

DIAN answered concerns in connection with the adjustments in transfer pricing studies as a response to the change in the accounting systems, with the entry into force of IFRS


DIAN, in its Revenue Ruling No. 0728 of July 21, 2016, answered a series of questions related to the implementation of International Financial Reporting Standards (IFRS) and their impact in transfer pricing rules.

The Ruling determines that, to the extent that the variation between IFRS and COLGAAP accounting systems is carried through the system of mandatory or tax book records, according to Article 3 and 4 of Decree 2548 of 2014, this should not interfere with determining the tax base under the arm’s length principle.

On the other hand, it is noted that in the transfer pricing information return, it must be recorded the accumulated reportable transactions entered into with related parties abroad or entities located in tax free zones, using the respective accounting frameworks applicable in the respective year.