APAs Implementation and Benefits in Colombia: Practical Guide

May 3, 2024

Introduction to the APA Concept

Advance Pricing Agreements (APAs) are treaties between taxpayers and the DIAN (Dirección de Impuestos y Aduanas Nacionales – National Tax and Customs Directorate) of Colombia to predefine Transfer Pricing (prices or values agreed upon in related-party transactions). These agreements are fundamental to guarantee the correct taxation of intra-group transactions, increasing legal certainty and tax predictability.  

APA Application Process

The APA procedure in Colombia includes several essential steps, starting with a preliminary meeting and filing a formal request detailing the transactions included and the proposed Transfer Pricing methodologies. This process requires thorough documentation and support for the transactions and assumptions used.  

DIAN Evaluation and Approval

Once filed, the DIAN evaluates the request, which may require adjustments or clarifications. This process may be accepted or rejected, including coordination with other tax jurisdictions for bilateral or multilateral agreements.  

Implementation and Follow-up

Once an APA is approved, companies must strictly follow the agreed terms by filing annual compliance reports. These reports are essential to demonstrate the applied prices comply with the terms of the agreement, maintaining the effectiveness thereof during its effectiveness.  


APAs represent a valuable tool for tax risk management and tax compliance in Colombia, allowing companies to operate more transparently and confidently in their international transactions. Through a thorough understanding and a proactive approach, companies can maximize the APAs’ benefits and strengthen their global tax position.