Colombia master file and local file requirements (2026)

Do I need a master file and local file in Colombia?

You need a local file if the Colombian entity passes either size test and transacted with a foreign related party or a free trade zone party. Gross equity of 100,000 UVT at year end is one test. Gross income of 61,000 UVT for the year is the other. The master file is added where the taxpayer belongs to a multinational group, meaning two or more companies tax resident in different jurisdictions.

Colombia then adds a trigger most regimes do not have. Dealings with a party in a non cooperative, low tax or preferential regime jurisdiction require a local file once they pass 10,000 UVT a year, whether or not that party is related to you. The list of those jurisdictions was refreshed with effect from 1 January 2025^[1].

Every threshold is stated in UVT, Colombia's tax value unit, and the unit is reindexed to inflation each year. That is why each figure above carries the year it applies to. The unit was COP 49,799 for the 2025 tax year, and the tax authority set it at COP 52,374 for 2026^[2].

Who counts as a related party in Colombia?

A party is related when it holds more than 50% of the capital, directly or through subsidiaries, when it controls a majority of the board, or when it has a right to 50% of the profits. The OECD country profile for Colombia^[3], updated in May 2025, sets out the full list.

Relatedness is not the only route into the regime. A transaction with a party in a non cooperative or preferential regime jurisdiction is documented on its size alone, which catches groups that have no related party in Colombia at all.

What are Colombia's master file requirements?

The master file is required where the taxpayer meets the local file thresholds and belongs to a multinational group. It is filed alongside the local file on the September schedule, not kept on hand.

It describes the group rather than the Colombian entity: the global business lines, the intangibles, the intercompany financing arrangements, and how income and economic activity are spread across jurisdictions. The content rules have been in place since 2017^[4]. In practice the data comes from the parent, so a Colombian subsidiary cannot file without it.

What are Colombia's local file requirements?

The local file documents the Colombian entity's controlled transactions, its functional analysis, the method chosen for each transaction and the benchmarking behind it. A transaction type worth 45,000 UVT or less in the year drops out of the documentation entirely.

Colombia accepts pan regional comparables, so a benchmarking set does not have to be Colombian. That matters because local comparables often do not exist for a given transaction type, and building a Colombia only set is usually the most expensive way to reach the same answer.

Does Colombia require country by country reporting?

Yes, for a Colombian resident ultimate parent, or a surrogate filer, of a group whose consolidated accounting revenue reached 81,000,000 UVT or more in the immediately preceding year. The report is due on the tenth business day of December, which is 15 December 2026, and the stagger by tax ID digit does not apply to it.

A Colombian member of a foreign group still has a notification duty. It has to tell the tax authority whether it is the reporting entity and, if it is not, name the entity that is and where that entity is tax resident. Colombia has been exchanging reports automatically with partner administrations since signing the multilateral agreement on 21 June 2017.

What is Form 120, Colombia's transfer pricing informative return?

Form 120 is a return, not a document you hold. It is filed with the tax authority in the same September window as the master file and the local file, and it is a separate obligation from both. Who files it follows the same 100,000 UVT equity and 61,000 UVT income tests used for documentation.

Guides routinely fold Form 120 into the word "documentation" and miss that it is a filed return with its own number and its own sanction scale. No separate threshold for the return itself is confirmed from a primary source, so this page states none.

When are Colombia's transfer pricing deadlines in 2026?

Documentation and Form 120 for the 2025 tax year are filed electronically between the seventh and the sixteenth business day of September 2026, which runs from 9 to 22 September, ordered by the last digit of the tax ID. The tax authority confirmed the opening date^[5] for the 2025 tax year.

Against a 31 December year end the documentation window opens about nine months later, and country by country reporting closes the year in mid December. The filing calendar itself has been fixed since 2023^[6].

What language and currency do the files require?

The local file is in Spanish, although foreign comparables data inside it may stay in English. The master file may be submitted in English. The tax authority can ask for an official translation and give you 20 business days to produce it. The currency amounts must be expressed in is not confirmed from a primary source, so this page does not state one.

What are the penalties for getting Colombia transfer pricing wrong?

Sanctions are graduated and run on two separate scales, one for the informative return and one for the supporting documentation. Late filing, inconsistency, omission and correction each carry their own rate, and omitted transactions are sanctioned more heavily than inaccurate ones.

Correcting before the tax authority issues its notice cuts the sanction to 50%. That reduction cannot be stacked with the general reduction available elsewhere in the tax code, a point the authority confirmed in a 2025 ruling. The peso and UVT amounts behind each scale could not be verified against a primary source, so this page publishes the structure and not the figures. Check the amounts with your Colombian adviser before you budget for them.

What is the parent company exposed to?

A Colombian subsidiary's filing failure lands on the group. The master file is built from group level data, so a parent that does not supply it leaves the subsidiary unable to file at all. Country by country notification names the parent and its tax residence, which is an easy thing for a headquarters that files its report elsewhere to overlook.

The downstream risk is money rather than paperwork. Disallowed deductions and pricing adjustments raise the Colombian effective tax cost, and that flows into consolidated results.

How does Colombia compare with the OECD baseline?

Colombia joined the OECD in April 2020^[7] and is an Inclusive Framework member, and its regime follows the OECD Transfer Pricing Guidelines closely. The Guidelines are not written into Colombian law. A 2003 Constitutional Court ruling treats them as an interpretive aid.

Three differences are worth planning around. Form 120 has no OECD equivalent. The non cooperative jurisdiction trigger pulls in transactions with no related party behind them. And Colombia files its documentation rather than holding it, on a calendar whose thresholds move every year with the tax value unit.

How we help with Colombia transfer pricing

Colombia hands a group three filings in one September window, on a date that moves with its own tax ID, and thresholds that are restated every January. We build the benchmarking and the functional analysis, draft the local file in Spanish and the master file, prepare Form 120, and file all three before the entity's date in the stagger. See how our transfer pricing software works.

Book a demo to get a Colombia transfer pricing exposure review before the September window opens.