On 3 May 2017, the Colombian Tax Authority (DIAN) clarified the fiscal years for which the new transfer pricing obligations established in Article 108 of Law 1819 of 2016 will apply. According to Law 1819, taxpayers have to file a local file, master file and country-by-country (CbC) report.
Local file must be filed between 11 July and 25 July for tax year 2016, based on the last number of the taxpayer’s ID, as established in Decree 1625 of 2016.
Master file must be filed for tax year 2017 in 2018 according to dates to be determined by the Government. Tax year 2016 is not subject to the master file requirement.
CbC report must be filed for tax year 2016, as included in Article 108 of Law 1819 of 2016. The Government has not established the filing dates, but they cannot be earlier than 31 December 2017.
Colombian transfer pricing regulations require some taxpayers to file a transfer pricing return on the same date as the local file.