Transfer Pricing Challenges in Commodity Transactions: A Review of Case Law from Colombia

The global commodities market has experienced a significant resurgence over the past two centuries. For transfer pricing purposes, it is essential to verify that the prices agreed between associated companies in commodity transactions have been established in market conditions, considering the relevant circumstances and risks assumed by the parties. The proper application of transfer pricing regulations in commodity transactions is relevant when disputing with tax authorities. In this article, the author explains transfer pricing challenges in commodity transactions through a review of Colombian case law, examining local experience and the latest pronouncements on such matters.