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DECREE OF THE MINISTRY OF FINANCE

Colombian tax residents obliged to submit the Local File, Master File and Country by Country report 

The Decree 2120 of 2017 establishes the income tax taxpayers who are liable of submitting the informative return of transfer pricing, preparing and filing the Local File, the Master File and the country-by-country report

 

The Decree 2120 of 2017 establishes the income tax taxpayers who are liable of submitting the informative return of transfer pricing, preparing and filing the Local File, the Master File and the country-by-country report, according to their gross equity, gross income, the operations performed, their location and nature, among others. For purposes of determining if a company has the obligation of filing the aforementioned reports, a case-by-case analysis should be made according to the requirements established by article 260-5 of the Tax Statute and the Decree 2120 of 2017 (Decree 2615 of 2016).

In relation to the aforementioned, the Colombian Tax Authority established the terms, conditions and technical specifications related to the submission of the country-by-country report regarding the transfer pricing regimen corresponding to fiscal year 2016.