Colombian Tax Authority Clarifies CUP Method May be Used for Commodity Transaction that Lack Quoted Reference Price

The Colombian tax authority (DIAN) recently published Ruling 1118 (Int. 81) of 13 February 2024 on whether the Comparable Uncontrolled Price (CUP) method can be used for a commodity transaction carried out between related parties that lacks a quoted price as a reference. The ruling confirms that in such cases, the CUP method can be used, in which case the taxpayer can establish the arm's length price by referring to uncontrolled transactions that are comparable to the controlled transaction.…