The DIAN (Dirección de Impuestos y Aduanas Nacionales – National Tax and Customs Directorate) has confirmed that the deadlines for formal compliance with Transfer Pricing obligations for the 2024 fiscal year, as well as part of 2025, will commence on September 9, 2025.
Main Obligations, Deadlines, and Available Tools
1. Transfer Pricing Information Statement – Form 120
Taxpayers who are required to file this form must do so electronically through the DIAN’s electronic services.
2. Supporting Documentation
It includes the Local File (specific taxpayer operations), the Master File (comprehensive or general for the multinational group), and the Country-by-Country Report, which has a deferred filing deadline until December 2025.
3. Available Tools
Since June 2025, the DIAN has made the following available to taxpayers:
- The Form 1125 pre-validator, version 3.6.1.25, is for generating the XML file.
- The computer system for uploading and sending the XML file through the “information submission by file transfer” service.
Specific Dates and Penalty Regime
According to Press Release No. 099, the filing deadline of the information statement and supporting documentation will range between the seventh and sixteenth business days of September, which for 2025 corresponds to September 9 and 22, and is subject to the last NIT digit.
The DIAN emphasizes that non-compliance may result in fines, tax adjustments, or possible exhaustive audits. Therefore, timely compliance with all deadlines is essential.
Regulatory Background and Relevance of the Regime
- Decree 2229 of 2023 and the DUT (Decreto Único Tributario – Tax Single Decree) 1625 of 2016, as amended, regulate the deadlines and requirements for Transfer Pricing, establishing the dates, conditions, and formal responsibilities according to the type of taxpayer and their tax periodicity.
- The BEPS regulations (OECD Action 13) include documentation obligations such as filing the Local File, Master File, and Country-by-Country Report, designed to increase transparency in related-party transactions and prevent abusive profit-shifting practices.
- Failure to file such documentation may result in tax recalculations, duplication of the tax base, financial penalties, and greater risk of challenges to tax audits.
Recommendations for Taxpayers
- Strategic planning: Begin gathering information and preparing reports promptly, especially since the Country-by-Country Report is due by December 2025.
- Use of e-tools: Download the Form 1125 pre-validator, generate the XML file with Form 120, and upload it through DIAN’s IT systems. This ensures your filing meets all technical requirements.
- Internal control and external consultation: Strengthen internal tax governance to ensure consistency, integrity, and regulatory updates. For complex cases, consult specialized Transfer Pricing firms to help ensure full compliance.
Conclusion
In summary, large taxpayers in Colombia must submit the required Transfer Pricing information statement and supporting documentation for the 2024 fiscal year between September 9 and 22, 2025, using e-tools and following the schedule based on their last NIT (Número de Identificación Tributaria – Tax Identification Number) digit. Meeting these requirements demands precision, timeliness, and thoroughness in documentation, and is the most effective way to avoid penalties and tax adjustments.
Source: DIAN