Nullity of DIAN concepts

The report examines the legal, economic, and accounting consequences arising from the invalidation of opinions issued by the DIAN in Colombia. Legally, the invalidation of an opinion retroactively removes it from the legal system, rendering it uninvokable in the future and weakening previous administrative acts based on it, although it respects established legal situations.

Economically, annulment can both strengthen legal certainty by correcting erroneous interpretations, which benefits long-term investment, and generate short-term uncertainty due to retroactive doctrinal changes. From an accounting perspective, annulment requires companies to evaluate and record, if probable, new uncertain tax obligations as liabilities or provisions, or disclose them as contingencies, adjusting financial statements and deferred taxes in the period in which the judgment is known.