Global Tax Alert (News from Americas Tax Center and Transfer Pricing) | 9 May 2017

Colombian Tax Authority clarifies filing obligations under BEPS Action 13

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On 3 May 2017, the Colombian Tax Authority clarified the fiscal years for which the new transfer pricing obligations established in Article 108 of Law 1819 of 2016 will apply.

On 29 December 2016, the Colombian Congress enacted Law 1819, which includes rules related to the implementation of Action 13 of the Organisation for Economic Co-operation and Development’s Action Plan on Base Erosion and Profit Shifting (BEPS) in Colombia. Under Law 1819, taxpayers must file a local file, master file and country-by-country report as follows:

  • Local file: Must be filed for tax year 2016 between 11 July and 25 July, depending 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 in accordance with dates to be determined by the Government; tax year 2016 is not subject to the master file requirement
  • Country-by-country 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 information return on the same date as the local file. These rules have not been modified.

For additional information with respect to this Alert, please contact the following:

Ernst & Young SAS., Bogotá
  • Andrés Parra
    +57 1 484 7600
    andres.parra@co.ey.com
  • José E Guarín
    +57 1 484 7671
    jose.guarin@co.ey.com
  • Mónica Piedrahita
    +57 1 484 7319
    monica.piedrahita@co.ey.com
Ernst & Young LLP, Latin American Business Center, New York
  • Ana Mingramm
    +1 212 773 9190
    ana.mingramm@ey.com
  • Enrique Perez Grovas
    +1 212 773 1594
    enrique.perezgrovas@ey.com
  • Pablo Wejcman
    +1 212 773 5129
    pablo.wejcman@ey.com
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
  • Jose Padilla
    +44 20 7760 9253
    jpadilla@uk.ey.com

EYG no. 02099-171Gbl