NewsFlash January – 2024

Upcoming transfer pricing due dates in the Americas   

Bolivia: January 28, 2024 

  • Deadline for mining companies to submit Informative Sworn Statement (F.601) and Local Report. 

Colombia: transfer pricing deadlines for fiscal year 2023 are established 

DIAN, the Colombian tax authority, issued Decree 2229 of 2023, which establishes new deadlines related to the submission of transfer pricing documentation for fiscal year 2023 and subsequent years.    

This decree modifies the due dates of the last years, unifying a single due date for the supporting documentation. This change means that the Master File deadline is brought forward from December to September. Likewise, a single deadline was established for the Country-by-Country reporting obligation. For 2024 and onward, the deadlines are as follows: 

To consult the decree, click here  

Ecuador: tax authority issues new Transfer Pricing Analysis Standardization Technical Sheet, applicable as of fiscal year 2023 

This update of the technical sheet establishes substantial changes in the content of the comprehensive transfer pricing report to be filed in 2024 for fiscal year 2023. The main changes include:  

  • The form of presentation of the report; submissions can now be made digitally by all taxpayers. 
  • Inclusion of information related to accounting, specifically of the account where the transaction subject to report was recorded.  
  • Expansion of the information related to intangible transfer operations, and financing and investment operations.  
  • Inclusion in the comprehensive report of more information related to the multinational group that is usually reported in the Master File.  
  • Inclusion of more information on the local company, including more detailed organizational structure, hierarchical dependence, target market, business strategy, business restructurings and previous valuation agreements.   
  • Changes to the calculation formulas for the application of adjustments.  
  • Changes to, and requests for, more information about the selection of comparable companies.  

To consult the new Fact Sheet, click here. 

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