NOTICE – COUNTRY-BY-COUNTRY REPORT

The dates for filing the notice have changed- Country-by-Country report. All Income Tax contributors that are part of a multinational group must file the aforementioned notice, regardless of whether they are not obligated to file a Transfer Pricing Informative Return.  

On June 25, 2024, the National Directorate of Taxes and Customs, [in Spanish: la Dirección de Impuestos y Aduanas Nacionales], (DIAN), published Resolution 5744 which amended the terms for filing a Country-by-Country Report. (Resolución 005744 de 25-06-2024.Pdf (dian.gov.co). 

In general, the Country-by-Country notice is carried out by contributors who are obligated to file their Transfer Pricing Informative Return. It consists in notifying the National Directorate of Taxes and Customs, [DIAN], if the contributor who joins a Multinational group, and for tax purposes, resides in Colombia, is the parent entity or controlling company, or the substitute entity that is designated to submit the Country-by-Country report. If this is not the case, then the identity and tax residence of the reporting entity must be reported. Such notice takes effect when the tax return is filed.

Moreover, the National Directorate of Taxes and Customs, [DIAN], announced that taxpayers who are not obligated to file a Transfer Pricing Informative Return are also obligated to comply with this obligation on the due dates of the aforementioned tax return, thereby unifying the obligations of all taxpayers subject to this regime. 

Those taxpayers who must only file country-by-country notification must do so by using the established format of the the National Directorate of Taxes and Customs [DIAN]. Once the form has been filled in, it must be sent via e-mail and follow the procedure as indicated in Resolution 005744 by September at the latest, in accordance with the last digit of your Taxpayer ID Number [in Spanish: NIT].

The content of this newsletter is merely informative, that´s why it cannot be used under any circumstances as advice on the matter described in it. If you need advice on any of the aspects discussed, our team of professionals will be willing to assist you. contacto@jadelrio.com