Usually not. First, the report applies only to very large groups: those with consolidated revenue of 81 million UVT (Colombia's tax value unit) or more. For the tax year 2025 report, that is about COP 3.8 trillion, or roughly USD 940 million. If the group is above that threshold and its ultimate parent files in a country that exchanges these reports with Colombia, as the United States does, the Colombian subsidiary only has to tell the DIAN, Colombia's tax authority, who filed it (that notification was due in September). The subsidiary files in Colombia only in a few cases, explained below. The report for tax year 2025 is due December 15, 2026.
What is the country-by-country report?
It is the report a multinational group gives tax authorities with its figures broken down by country: revenue, profit before tax, income tax paid and accrued, stated capital, retained earnings, number of employees and tangible assets other than cash. It also lists each group company, where it is resident and what it does.
In Colombia it is part of the transfer pricing rules: it is one of the pieces of supporting documentation under article 260-5 of the Tax Code (Estatuto Tributario), along with the local file and the master file. Its rules are different, though. The local and master files generally depend on having related-party transactions and on the company's own equity or revenue exceeding certain thresholds. The country-by-country report depends on the size of the whole group and on the cases explained below. It is an information return and creates no tax liability. Failing to comply is penalized under article 651 of the Tax Code.
First: is your group above the threshold?
The report applies only to multinational groups whose consolidated revenue was 81 million UVT or more in the year before the reported year. This is the whole group's worldwide revenue, per the ultimate parent's consolidated financial statements. Revenue in Colombia matters only for the 20% case explained below.
The UVT is Colombia's tax value unit, updated every year. At the 2024 UVT (COP 47,065), the threshold is about COP 3.8 trillion. At the average 2024 exchange rate (COP 4,072.59 per dollar), that is roughly USD 940 million. We use 2024 figures because, for the tax year 2025 report, the group's 2024 revenue is what is compared. If group revenue is close to the threshold, the conversion method deserves a careful look.
If the group is below that threshold, neither the group nor its companies have this obligation in Colombia.
Who files it?
| The group's situation | What the Colombian subsidiary does |
|---|---|
| Below the threshold | Nothing |
| Above the threshold, and the ultimate parent files in a country that exchanges these reports with Colombia (the United States, for example) | Only notifies the DIAN who filed |
| Above the threshold, the ultimate parent does not file in a country that exchanges these reports with Colombia, and the group's Colombian companies account for less than 20% of the group's consolidated revenue | Only notifies, unless the group designates it to file |
| Above the threshold, the ultimate parent does not file in a country that exchanges these reports with Colombia, and the group's Colombian companies account for 20% or more of the group's consolidated revenue | Files in Colombia, except in the cases below |
| Above the threshold, and the group designates the Colombian subsidiary to file on its behalf | Files in Colombia |
If the group is above the threshold and the ultimate parent files in a country that exchanges these reports with Colombia, such as the United States, the second row applies. The other rows come with conditions worth checking in detail.
When the subsidiary files
When the group designates it. The rule calls it the "surrogate parent entity." The ultimate parent can designate it only when the parent itself is not required to file at home, when its country does not exchange these reports with Colombia, or when the DIAN has notified a systemic failure by that country.
When the Colombian companies account for 20% or more of the group's consolidated revenue and the ultimate parent did not file. Under the rule, the ultimate parent "did not file" if its country has no legal filing requirement, if, on the filing date, its country has no agreement in force with Colombia to exchange these reports, or if the DIAN has notified the subsidiary of a systemic failure by that country. Even then, the subsidiary does not file in two situations:
- when another group company filed as surrogate parent entity in a country that exchanges these reports with Colombia, within 12 months of the group's fiscal year-end, among other conditions, and the subsidiary notified the DIAN who filed;
- when group revenue did not exceed the filing threshold of the ultimate parent's country.
If several group companies in Colombia must file, the one the group designates files, or, if none is designated, the one with the largest net worth (patrimonio) in Colombia on December 31 of the reported year.
There is one more case, which does not involve a subsidiary: a Colombian company that is the ultimate parent of a group with companies abroad files when its group is above the threshold.
What if the ultimate parent is in the United States?
In the United States, the ultimate parent of a group with revenue of USD 850 million or more in the preceding year files the report with the IRS on Form 8975, attached to its income tax return. The United States and Colombia have had an agreement to exchange these reports in force since August 30, 2017.
So, in practice, if the group's ultimate parent is in the United States and files Form 8975, the Colombian subsidiary does not have to file in Colombia, as long as the agreement remains in force and the DIAN has not notified a systemic failure. What it does do is the notification. If the U.S. company is itself owned by a group based in another country, the analysis follows the country of the ultimate parent.
The notification to the DIAN
Every company resident in Colombia that belongs to a group above the threshold must notify the DIAN whether it is the ultimate parent or the surrogate parent entity, or, if it is neither, which entity files the report and where that entity is resident.
- If it files the transfer pricing information return (Form 120), the notification goes in that same return, in boxes 37 to 44.
- If it does not, it fills out the form the DIAN publishes for this purpose and emails it to preciostransferencia@dian.gov.co, with the subject line "Notificación – Informe País por País" followed by the tax year.
The deadline falls between the seventh and the sixteenth business day of September, depending on the last digit of the company's tax ID (NIT). For the tax year 2025 report, that deadline was in September 2026.
When and how is the report filed?
A company that has to file in Colombia does so by the tenth business day of December, regardless of the last digit of its tax ID (NIT). For the tax year 2025 report, the deadline is Tuesday, December 15, 2026.
It is filed online through the DIAN's electronic services, using the file upload option: an XML file in DIAN format 5254, following the DIAN's CbC XML v2.0 technical annex, with an electronic signature. The DIAN warns that activating the electronic signature less than three business days before the deadline does not justify late filing.
What to do with this
- Check the group's consolidated revenue for the year before the reported year (for the 2025 report, 2024 revenue) against the threshold of about COP 3.8 trillion.
- Confirm which entity files the report and in which country, and whether the group designated a company to file on its behalf. The subsidiary needs that entity's name and tax residence for its notification to the DIAN.
- Make sure the notification was made in the transfer pricing information return or by email to the DIAN. If it was not, it is worth making it as soon as possible.
- If your subsidiary has to file, have the file and the electronic signature ready before December 15, 2026.
Sources
- Colombian Tax Code, art. 260-5 (supporting documentation), opening paragraph, numerals 1 and 2 and parágrafo 1 — Senate General Secretariat
- Decree 1625 of 2016, arts. 1.2.2.2.3.1 to 1.2.2.2.3.7 (country-by-country report) and arts. 1.6.1.13.2.28 and 1.6.1.13.2.29 (deadlines, replaced by Decree 2229 of 2023) — DIAN regulatory database
- DIAN Resolution 000227 of 2025, arts. 1.6.3.1 to 1.6.3.7 (filing) and 1.6.4.5 (notification) — DIAN regulatory database
- 2024 UVT: DIAN Resolution 000187 of 2023 — DIAN regulatory database
- Average 2024 exchange rate (TRM), with Banco de la República data — Actualícese
- IRS, Instructions for Form 8975 — irs.gov
- IRS, Country-by-Country Reporting Jurisdiction Status Table — irs.gov