What is it?

The numerous operations in international trade, the high level of integration of operations, as well as the hemispheric tendency of the tax authorities to implement controls on taxes, have led to the determination of Transfer Pricing and allocation of income and assets. For taxpayers this is an aspect of fundamental importance in the agendas of multinationals and tax authorities.

The amendments applied to article 108 of Law 1819 of 2016, seek to improve the scope of the documentation proving transfer pricing, bringing in line the new international standards established in the result of Action 13 of the BEPS OECD / G20 project.

Those bound to this Regime, are taxpayers of the income tax that during the year 2017 have made operations with entities or persons linked from abroad or located in the free zone of Colombia, or who have carried out operations with persons or entities located in countries or territories denominated "tax havens".

It is a condition that at the end of fiscal year 2017, taxpayers have had a gross equity equal to or greater than 100,000 UVT (COP 3,185,900,000) or that during that fiscal period their gross income would have been equal to or greater than 61,000 UVT (COP 1,943,399,000).

Our approach

Our multidisciplinary group of professionals is trained to offer you the following services:

  • Preparation and presentation of the supporting documentation - transfer pricing report - and of the individual and consolidated informative declarations, required by the DIAN.
  • Preparation of the study of attribution of income and patrimony for permanent establishments and / or branches, required by the DIAN.
  • Assistance in the planning and restructuring of existing intercompany operations or prospective analysis of new intercompany operations.
  • We carry out the loading and sending of the following annual transfer pricing statements:
  • Local informative statement of related parties.
  • Master informative statement from related parties.
  • Informative declaration country by country of the multinational business group.
  • Defense in audits, attention to requirements and litigation.
  • Advice on the development of transfer pricing policies.
  • Coordination of documentation of transfer prices at regional and global level.
  • Design, documentation and drafting of Advance Price Agreements (APA) to be subscribed with the DIAN in the determination of the price or profit margin of the different operations carried out with related parties or economic parties.

Our specialist team

Led by Lic. Estanislao Milicich who, during more than 15 years of intense activity, has participated as a principal consultant in more than 250 planning and documentation projects with local, regional and global reach in direct coordination with professionals from Atlanta, California, Washington and Chicago. The projects coordinated, supervised and developed by Estanislao, include several industries: bioscientific, automotive, energy, construction sector, chemicals, telecommunications, public services, agriculture, financial services, high technology and mass consumption.