1. The Suporting Transfer Pricing Documentation or report.

We elaborate the transfer pricing report in Colombia, according to the article 260-5 of the Tax Code. This article indicates that the report must content the master file and the local file.

2. Advice on the transfer pricing information statement.

Advise in the fullfiment of the Transfer Pricing Informative Declaration in Colombia, according to the article 260-9 of the Tax Code. 

3. Advice in Transfer Pricing determination process.

This service include an diagnostique of the arguments and conclusion that DIAN arrived, the strategy, the document with technical arguments and the results, in order to give a complete advice in fiscalizations or requeriments os the Tax Authorities in Transfer Pricing in Colombia.

4. Advice in the negotiation of Prior Agreements with the Administration (APA´s).

APAs are agreements between taxpayers and the tax administration, which seek to establish a valuation for transfer pricing, in advance, of transactions between related parties, and / or transactions with countries or Territories of low or zero taxation. Thus, a process is initiated in which an agreement must be reached on certain technical aspects, the most important being the following: the method allowed by the standard to be applied, comparison criteria and adjustments. Our service includes the elaboration and accompaniment until the effective celebration of the APA with the Tax Administration.

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