Colombia Transfer Pricing Documentation Requirements
Colombia ties its Local File and Master File obligation to a combination of asset or income thresholds and per-type transaction limits expressed in tax units, alongside a transfer pricing informative return. Penalties are calculated on the value of the documented transactions and are subject to defined caps.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Triggered with the Local File: gross assets > 100,000 UVT or income > 61,000 UVT, and transactions per type > 45,000 UVT | By the filing deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | EN / ES | Yes (0.05% to 0.2% of documented transactions, capped) |
Local File Required | Gross assets > 100,000 UVT or income > 61,000 UVT, and transactions per type > 45,000 UVT | By the filing deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | ES | Yes (0.05% to 0.2% of documented transactions, capped) |
Informative return Annual filing | Gross equity ≥ 100,000 UVT or gross revenue ≥ 61,000 UVT | September of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes |
CbC report Required | Group revenue ≥ COP 3,435,372m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
A Colombian entity must prepare the Local File, and with it the Master File, where it transacts with related parties and meets a size test combined with a transaction test. The size test is gross assets exceeding 100,000 tax units or gross income exceeding 61,000 tax units, and the transaction test is intercompany transactions of a given type exceeding 45,000 tax units. Where transactions involve tax havens or preferential regimes, additional rules apply. The documentation is produced within 15 days of a request.
Distinctive features of the Colombian regime
The defining feature of the Colombian regime is the value-based, capped penalty structure for the documentation, paired with a separate informative return. Late filing within five business days of the deadline attracts 0.05 percent of the total documented transactions, subject to a cap, while filing more than five days late attracts 0.2 percent per month or part-month, subject to a higher cap. The transfer pricing informative return is filed by a scheduled date in September of the following year, geared to the last digit of the tax identification number, and is required where gross equity reaches 100,000 tax units or gross revenue reaches 61,000 tax units. There is no formal safe harbour.
Benchmarking and comparables
There is no requirement or preference for local comparables, and all jurisdictions may in principle be included, although any geographic filter must be supported in the search strategy, and benchmarks drawn from Europe, Asia, the Middle East, or other continents cannot be used; local, Americas, or global analyses are acceptable. Single-year testing is the general rule, with a multi-year approach available in extraordinary circumstances where technical, economic, and financial arguments support it in the Local File. There is no rule requiring a fresh search every year, although the comparability of the set must be re-evaluated, and the search date and any financial updates must be disclosed. The limitation period for transfer pricing assessments is five years.
Frequently asked questions
Which comparables can a Colombian Local File rely on?
Local, Americas, or global benchmark analyses can be used. Benchmarks drawn from Europe, Asia, the Middle East, or other continents cannot be used, and any geographic filter applied must be supported in the search strategy.
How are Colombian documentation penalties calculated?
Late filing within five business days attracts 0.05 percent of the total documented transactions, subject to a cap, while filing more than five days late attracts 0.2 percent per month, subject to a higher cap.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.