TRANSFER PRICING OBLIGATIONS 2023

Taxpayers who engaged in transactions with related parties located abroad and free trade zones during the year 2022 are obligated to comply with the transfer pricing regime. They must prepare the supporting documentation (local report and master file, the latter in case of being part of a Multinational Group) and an informative statement if they have a gross equity equal to or greater than 100,000 UVT ($3,800,400,000) or gross income equal to or greater than 61,000 UVT ($2,318,244,000).

It’s important to note that if transactions were conducted with non-cooperating jurisdictions, those with low or no taxation, and preferential tax regimes, an informative statement and supporting documentation must be submitted without having to meet the mentioned minimum thresholds. However, there is no need to prepare and submit the Local Report for the supporting documentation when the annual accumulated amount of transactions does not exceed the equivalent of 10,000 UVT for the taxable year for which the supporting documentation is prepared.

The deadlines for submitting the local report and the informative statement (corresponding to the taxable year 2022) are from September 7th to September 20th, 2023, depending on the last digit of the Tax ID, as follows:

On the other hand, the deadlines for submitting the Master File will be between December 11th and December 22nd, 2023, as follows:

Non-compliance with this regime carries the imposition of penalties.