Colombia’s Tax Landscape Shifts: Revised Deadlines for Transfer Pricing Documentation

January 31, 20240


Decree 2229, dated 22 December 2023, has ushered in a substantial shift in the timeline for the submission of essential transfer pricing documentation in Colombia. This decree, applicable to the tax year 2023 and beyond, mandates revised deadlines for various required forms, including the informative declaration, country-by-country (CbC) notification, Local file, Master file, and CbC report. The submission window for these documents now spans from the 7th to the 16th business day of September of the corresponding year, diverging from the traditional December deadlines observed in previous years. 


Significant Timelines Overhaul 

The most pronounced alteration introduced by Decree 2229 is the shift of transfer pricing documentation submission deadlines from December to September. This adjustment holds importance for businesses operating in Colombia, necessitating a recalibration of internal processes to meet the revised timelines. The change aims to enhance efficiency and streamline the compliance process, aligning it more closely with the tax year. 


Focused Attention on CbC Notifications 

For taxpayers exempt from submitting an informative declaration but affiliated with a multinational group, the obligation to submit a CbC notification looms large. Both the CbC notification and report are now due on the 10th business day of December, carving out a distinctive deadline for entities falling within this category. This adjustment reinforces the government’s commitment to transparency and thorough documentation, even for entities not obligated to furnish the informative declaration. 


Implications for Stakeholders 

The decree’s impact extends beyond mere adjustments to submission timelines; it highlights the government’s commitment to modernizing and refining transfer pricing compliance. The revised deadlines, coupled with the distinct requirement for CbC notifications, reflect Colombia’s dedication to aligning its tax regulations with international standards. This shift not only enhances the clarity of reporting but also serves as a proactive measure to combat potential issues related to transfer pricing practices within multinational groups. 


Conclusion: Navigating the New Norm 

For tax professionals, and businesses engaged in Colombian operations, staying abreast of these revised deadlines is imperative. The need for planning and adherence to the updated timeline is evident to ensure seamless compliance with the amended regulations. As these changes become effective for the tax year 2023 and onwards, the Colombian tax landscape takes on a new shape, emphasizing the importance of agility and adaptability in navigating these evolving regulatory waters. 


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