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 lengt…