The National Tax and Customs Directorate (DIAN) announced the activation of the pre-validator and the IT system for filing the Transfer Pricing Informative Affidavit (Form 120) for the 2025 tax year.
With this update, taxpayers subject to the regime can now begin preparing the required information, keeping in mind that the deadline for complying with this obligation is September 22, 2026.
Tools Available to Taxpayers
The DIAN has made the necessary tools available to taxpayers for preparing and filing the information required under the Transfer Pricing regime, including:
- The Transfer Pricing Pre-Validator (Form 1125, Version 13) for the 2025 tax year, which is identified on the agency’s website as “Transfer Pricing (2025 Tax Year) Version 3.6.2-26.”
- The system for generating and uploading the XML file.
- Form 120, corresponding to the Transfer Pricing Informative Affidavit.
- The electronic services for submitting supporting documentation, when applicable.
The tax administration noted that the filing procedure remains unchanged from previous years. Consequently, taxpayers must download the pre-validator, generate the XML file, upload it to the “Submission of Information via File Upload” service, and, once it has been successfully validated and shows a “Successful” status, electronically file Form 120. The procedure is established in Resolution 1210 of August 5, 2022.
Points Requiring Special Attention
The DIAN emphasized certain operational aspects that taxpayers must consider to avoid errors during the filing process.
One of the key points concerns filling out the “Reported Year” field within the XML file. For the return corresponding to the 2025 tax year, that year must be entered. If, by mistake, the year 2026 is entered, the system will interpret the information as a partial-year return, resulting in an incorrect filing.
The agency clarified that the year 2026 should only be entered when the company is in the process of liquidation, in which case a partial-year return must indeed be filed.
Likewise, the DIAN reminded taxpayers that the Informative Affidavit must be signed and filed by the company’s legal representative, not by the statutory auditor. The obligation is considered fulfilled only when the entire procedure established in current regulations has been completed.
Supporting Documentation
The computer system is also available for submitting supporting documentation. For the 2025 tax year, the Local File is Form 1729, Version 8, while the Master File is Form 5231, Version 2; the filing deadlines for both are in December.
Both reports must be filed electronically through the DIAN’s online services, in PDF format and using the Electronic Signature Tool (IFE). Any subsequent corrections or replacements of the information must be made through the same channel.
Advance Planning to Mitigate Risks
Early access to these tools gives companies the opportunity to prepare, well in advance, the financial information and supporting documentation necessary to comply with the Transfer Pricing regime.
Given the level of technical detail required and tax authorities’ increasing focus on transactions between related parties, it is advisable to begin reviewing the information in a timely manner, validate the consistency of the reported transactions, and verify that the supporting documentation aligns with the requirements of Colombian regulations.
Preparing in advance not only facilitates timely compliance with formal obligations but also helps reduce tax contingencies arising from errors in filing or inconsistencies in the information provided.
At TPC Group, we have a team specializing in Transfer Pricing that assists domestic and multinational companies in preparing the Informative Affidavit, correctly validating the XML file, preparing supporting documentation, and ensuring full compliance with tax obligations in Colombia and throughout Latin America, thereby helping to reduce tax risks and strengthen regulatory compliance.
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