January 9, 2018 Colombia issues regulations on obligation to notify tax authorities about country-by-country report Taxpayers should review the new decree to determine whether they must file a CbC report. Colombia's tax authorities issued Regulatory Decree 2120 of December 15, 2017, which establishes the obligation for Colombian taxpayers to notify the tax authorities about whether they must file the country-by-country (CbC) report. The CbC report, which applies as of fiscal year 2016 (Article 206 — 5 of the Colombian Tax Code), contains information related to the global allocation of income and taxes paid by the multinational group, as well as information on the group's economic activities. The CbC report filing requirement applies to multinational groups that have recorded consolidated revenues (for accounting purposes) for fiscal year 2015 equal to or greater than 81 million Tax Value Units (around USD 800 million). Under the notification requirement, a taxpayer must inform the tax authorities as to whether it belongs to a multinational group and whether the multinational group must file the CbC report. If the multinational group must file the CbC report, the taxpayer must indicate the reporting company and the company's country of fiscal residence. The tax authorities have initiated the process of requesting the submission of the notification of the CbC report corresponding to fiscal year 2016. In most cases, the deadline to submit the notification is January 19, 2018. ———————————————
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