DIAN has reminded large taxpayers subject to the transfer pricing regime to make any required arm’s length adjustments in their 2025 income tax return and related filings, in line with Article 260-3 of the Tax Code and associated reporting obligations.
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return.
As filing deadlines approach, large taxpayers must ensure that their tax return reflects the necessary adjustments, where applicable, to comply with the arm’s length principle. This obligation is set out in Article 260-3 of the Tax Code. DIAN clarified that such adjustments must be included not only in the income tax return but also in Form 2516 – Fiscal Reconciliation Report, which is annexed to Form 110.
DIAN further noted that transfer pricing adjustments must be reported in the transfer pricing informative return, which is due to be filed in September. Specifically, taxpayers must disclose the adjusted income amount in Box 86. The same adjustments must also be documented in the local report forming part of the supporting documentation for the 2025 tax year.
For the purposes of the local report, DIAN recommends that taxpayers include detailed information on each adjustment, including the accounting account, description, accounting balance, adjustment amount, tax value, and the line or lines of the income tax return in which the adjustment was reported.
