During the past couple of years, Colombia has been implementing a Clearance-type e-invoicing mandate, much in line with trends that we have seen across the world. The speed in which DIAN, the Colombian tax authority, has introduced changes and rolled out the mandate is much higher than average, with momentum only having been overtaken by the Italian tax authority and its one-year implementation of its first e-invoicing mandate. However, this speed does indeed cast doubts and concern on its capability of being able to meet the mandated deadline of full implementation by 2019. Despite this, DIAN is once more confirming that they are more than ready for full implementation by expanding the mandate once again.
Recent developments in Colombia’s e-invoicing mandate
Resolucion 000010 of February 2018 mandates taxpayers categorized as Big Taxpayers during 2017/2018 (with some exceptions) to migrate to the new framework by June 2018. However, as stated in Colombia’s tax code (Article 684-2) taxpayers have a default additional 3 months to implement changes, which sets the final default deadline to September 2018.
The resolution allows taxpayers to apply for an extended grace period of up to three months to comply with the mandate, meaning that it could in theory, be possible for many taxpayers to obtain an extension to December 2018. To benefit from this possibility, taxpayers must file a formal application with DIAN by 1 June 2018 containing, among other things, a certified technical and/or functional justification of the request for additional time.
What could Resolucion 000010 really mean?
As we mentioned in our October article, the implementation of clearance frameworks often represent a heavy burden for taxpayers that must deploy a great number of resources to meet legal and technical requirements. The Colombian mandate will not be an exception. Considering that DIAN still has the possibility to outsource its clearance function to third parties (much like the Mexican model) and that such a change of orchestration means that technical changes are likely, if not inevitable, we at Sovos hope that the current speed of change will not mean a further need for adaptation in the near future, creating unnecessary cost for Colombian and international organizations doing businesses in the country.