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RULING OF THE SUPREME ADMINISTRATIVE COURT

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RULING OF THE SUPREME ADMINISTRATIVE COURT

Ruling of the Supreme Administrative Court regarding the favorability principle.

Ruling of the Supreme Administrative Court of November 12, 2015.

 

The Supreme Administrative Court modified the sanction imposed to a taxpayer for presenting extemporaneously the transfer pricing return for year 2010. Although the administrative acts were issued before the issuing of Law 1607 of 2012, the legal situation of the taxpayer at the moment was not consolidated. Therefore, the Supreme Administrative Court concluded that article 121 of law 1607 was applicable in accordance with the favorability principle, as the sanction for the taxpayer in these terms was less burdensome.