On December 13, 2024, the Colombian Ministry of Finance and Public Credit published the Executive Order 1,496 of 2024, modifying the list of non-cooperative and low or no taxation jurisdictions in Colombia.
This list is crucial to define the universe of transactions on which the transfer pricing analysis must be carried out.
As of January 1, 2025, the jurisdictions considered non-cooperative, and low or no taxation will be the following:
- Svalbard Archipelago
- Territorial Collectivity of St. Pierre and Miquelon
- State of Kuwait
- State of Qatar
- Independent State of Western Samoa
- Queshm Island
- Pitcairn, Henderson, Ducie and Oeno Islands
- Solomon Islands
- Labuan
- Macau
- Commonwealth of the Bahamas
- Kingdom of Bahrain
- Hashemite Kingdom of Jordan
- Cooperative Republic of Guyana
- Republic of Angola
- Republic of Cape Verde
- Republic of the Marshall Islands
- Republic of Liberia
- Republic of Maldives
- Republic of Nauru
- Republic of Trinidad and Tobago
- Republic of Vanuatu
- Republic of Yemen
- Helena, Ascension and Tristan de Cunha
- Sultanate of Oman
Therefore, the following have been excluded from the above list:
- Antigua and Barbuda
- State of Brunei Darussalam
- Grenada
- Hong Kong
- Cook Islands
- Commonwealth of Dominica
- Republic of Mauritius
- Republic of Seychelles
- Lebanese Republic
- Kitts & Nevis
- Saint Vincent and the Grenadines
- Saint Lucia
Consequently, transactions with non-related entities located in the twelve jurisdictions listed above dated after January 1, 2025 shall be excluded from the transfer pricing analysis.