Tax Law

Tax law attorney to respond to the DIAN, plan more effectively, and defend tax decisions.

Cafore Abogados supports individuals, companies, partners and estates when taxes stop being an accounting task and become a legal risk: DIAN inquiries, penalties, refunds, audits, tax planning and tax litigation.

DIAN Penalties Tax planning Litigio tributario Devoluciones Estate Business

A direct answer

What Cafore does in tax law.

A tax lawyer reviews economic facts, documents, deadlines, filings, evidence and arguments to prevent or defend tax disputes. At Cafore, the approach connects taxes with corporate matters, estates, contracts and administrative risk.

Published legal commentary and media presence.

El Tiempo Week Portfolio Media | Cafore Abogados. Press articles, interviews and media coverage of our firm. Legal Sphere Infobae
Cafore Abogados S. A. S. Bogotá, Colombia Tax law focused on strategy, evidence and decision About Us Team
01Pinpoint the problemFacts, urgency, and objective. 02Review the foundationDocuments, evidence, and connected risks. 03Pinpoint the litigationProceedings, actions, offenses, or authorities. 04Resolve doubtsQuestions grouped by moment and decision.

When it makes sense

Consult when a tax decision, inquiry, penalty, refund or estate reorganization needs legal defense and supporting documents.

An early review makes it possible to organize the facts, gauge the urgency, and avoid responses, signatures, or communications that could later weaken your legal position.

Common situation

DIAN inquiry.

A request, summons, assessment, penalty or inquiry has arrived that must be answered with supporting documents.

Common situation

Planning or reorganization.

The company or estate needs to decide before selling, inheriting, investing or reorganizing assets.

Common situation

Litigation or appeal.

An administrative act, balance dispute, denied refund or penalty already exists that must be challenged.

Quick assessment

Choose the starting point. The response changes according to the risk, the evidence, and the deadline.

Audit: what is best to organize first.

A request, summons, assessment, penalty or inquiry has arrived that must be answered with supporting documents. The initial review makes it possible to separate urgency, evidence and decision so that the next action is better supported.

Signs
  • DIAN inquiry
  • Defense before the DIAN
  • Corporate, estate, labor, consumer, accounting, customs and directors' liability matters
Documents
  • Inquiries, official acts, tax returns, receipts and prior responses
  • Contracts, invoicing, accounting and banking records
  • Corporate structure, beneficial owners and material transactions
Route
  • Assess deadlines and contingency
  • Organize tax evidence
  • Prepare a response, appeal or lawsuit

Documents, risks, and decisions

Risks, documents, and decisions worth organizing.

Each path links the main problem to the available evidence, the deadlines, and the consequences that may change the strategy.

01

Main risk

What usually prompts a tax law consultation.

01
Defense before the DIANCentral aspect

A defense before DIAN requires pinpointing facts, responsible parties, deadlines and concrete consequences. In tax law, that first reading determines whether it is best to prevent, negotiate, claim or prepare a formal action.

  • Facts that must be confirmed.
  • Evidence available and missing.
  • Practical consequence of acting or waiting.
02
Tax planningRisk that changes the strategy

Tax planning requires pinpointing facts, responsible parties, deadlines and concrete consequences. In tax law, that first reading determines whether it is best to prevent, negotiate, claim or prepare a formal action.

  • Facts that must be confirmed.
  • Evidence available and missing.
  • Practical consequence of acting or waiting.
03
Litigio tributarioRisk that changes the strategy

Tax litigation requires pinpointing facts, responsible parties, deadlines and concrete consequences. In tax law, that first reading determines whether it is best to prevent, negotiate, claim or prepare a formal action.

  • Facts that must be confirmed.
  • Evidence available and missing.
  • Practical consequence of acting or waiting.
04
Refunds and penaltiesRisk that changes the strategy

Refunds and penalties require pinpointing facts, responsible parties, deadlines and concrete consequences. In tax law, that first reading determines whether it is best to prevent, negotiate, claim or prepare a formal action.

  • Facts that must be confirmed.
  • Evidence available and missing.
  • Practical consequence of acting or waiting.
02

Evidence and documents

The documentary basis that allows decisions with less noise.

01
Inquiries, official acts, tax returns, receipts and prior responsesKey supporting document

Inquiries, acts, filings, receipts and prior responses help reconstruct the timeline, confirm what can be proven and detect gaps before responding, signing or escalating the conflict.

  • Source document and date.
  • Connection to the fact to be proven.
  • A safe way to request, preserve, or supplement the supporting document.
02
Contracts, invoicing, accounting and banking recordsDocument that organizes the evidence

Contracts, invoicing, accounting and bank records help reconstruct the timeline, confirm what can be proven and detect gaps before responding, signing or escalating the conflict.

  • Source document and date.
  • Connection to the fact to be proven.
  • A safe way to request, preserve, or supplement the supporting document.
03
Corporate structure, beneficial owners and material transactionsDocument that organizes the evidence

Corporate structure, beneficiaries and relevant transactions help reconstruct the timeline, confirm what can be proven and detect gaps before responding, signing or escalating the conflict.

  • Source document and date.
  • Connection to the fact to be proven.
  • A safe way to request, preserve, or supplement the supporting document.
04
Timeline of deadlines, notifications and paymentsDocument that organizes the evidence

A timeline of deadlines, notifications and payments helps reconstruct the timeline, confirm what can be proven and detect gaps before responding, signing or escalating the conflict.

  • Source document and date.
  • Connection to the fact to be proven.
  • A safe way to request, preserve, or supplement the supporting document.
03

Course of action

Options to correct, negotiate, claim, defend, or sue.

01
Assess deadlines and contingencyPossible decision

Measuring deadline and contingency is assessed according to urgency, available evidence, cost, counterparty and the expected legal effect. The right path is not always the most aggressive one; it must be the most sustainable.

  • Deadline and authority or opposing party.
  • The risk of negotiating, responding, or suing.
  • The specific outcome being sought.
02
Organize tax evidenceA path that must be measured with care

Organizing tax evidence is assessed according to urgency, available evidence, cost, counterparty and the expected legal effect. The right path is not always the most aggressive one; it must be the most sustainable.

  • Deadline and authority or opposing party.
  • The risk of negotiating, responding, or suing.
  • The specific outcome being sought.
03
Prepare a response, appeal or lawsuitA path that must be measured with care

Preparing a response, appeal or lawsuit is assessed according to urgency, available evidence, cost, counterparty and the expected legal effect. The right path is not always the most aggressive one; it must be the most sustainable.

  • Deadline and authority or opposing party.
  • The risk of negotiating, responding, or suing.
  • The specific outcome being sought.
04
Coordinate the patrimonial or corporate strategyA path that must be measured with care

Coordinating an estate or corporate strategy is assessed according to urgency, available evidence, cost, counterparty and the expected legal effect. The right path is not always the most aggressive one; it must be the most sustainable.

  • Deadline and authority or opposing party.
  • The risk of negotiating, responding, or suing.
  • The specific outcome being sought.
04

Connected risks

Matters from other practice areas that may change the strategy.

01
Corporate, estate, labor, consumer, accounting, customs and directors' liability mattersRelated risk

Corporate, estate, labor, consumer, accounting, customs and directors' liability matters may modify the main analysis because they connect tax law with other legal, financial, family, business or reputational risks.

  • Connected area and reason for the overlap.
  • Financial, operational or reputational impact.
  • Coordination needed before the next step.
02
Defense before the DIANA front that may broaden the case

A defense before DIAN may modify the main analysis because it connects tax law with other legal, financial, family, business or reputational risks.

  • Connected area and reason for the overlap.
  • Financial, operational or reputational impact.
  • Coordination needed before the next step.
03
Tax planningA front that may broaden the case

Tax planning may modify the main analysis because it connects tax law with other legal, financial, family, business or reputational risks.

  • Connected area and reason for the overlap.
  • Financial, operational or reputational impact.
  • Coordination needed before the next step.
04
Inquiries, official acts, tax returns, receipts and prior responsesA front that may broaden the case

Inquiries, acts, filings, receipts and prior responses may modify the main analysis because they connect tax law with other legal, financial, family, business or reputational risks.

  • Connected area and reason for the overlap.
  • Financial, operational or reputational impact.
  • Coordination needed before the next step.

Litigio tributario

Tax audits, penalties, appeals and tax proceedings.

Tax strategy changes according to the stage: inquiry, assessment, penalty, appeal, collection or lawsuit. Each response must be supported by accounting, evidence and timeliness.

Review a dispute

Proceedings before the DIAN and municipalities

  • Ordinary inquiry
  • Special inquiry
  • Formal summons
  • Official assessment
  • Statement of charges
  • Tax penalty
  • Third-party information reporting

Appeals and litigation

  • Motion for reconsideration
  • Direct revocation
  • Annulment and restoration of rights
  • Interim measures
  • Administrative litigation claim
  • Litigation settlement
  • Exhaustion of administrative remedies

Collection, balances and refunds

  • Administrative tax collection
  • Tax liens
  • Payment arrangements
  • Refund of favorable balances
  • Tax offsets
  • Amended returns
  • Income tax, VAT, ICA and withholdings

Corporate tax risks

  • Beneficial owner
  • RUB (Beneficial Owners Registry)
  • Accounting records
  • Electronic invoicing
  • Costs and deductions
  • Planning with substance
  • Liability of officers

Decision point

If you already recognize the main risk, we can review documents and define the next move.

Talk to Cafore

Before you write to us

Five documents for a first review.

Not all of them are required, but they help orient the consultation from the outset.

0 of 5 ready

The Cafore Method

A clear process to move from the problem to a course of action.

The review is not limited to citing rules. It seeks to identify what can be proven, what must be corrected and which decision is best to carry out.

1

Context

We understand the decision, dispute or document that prompted the consultation.

2

Documents

We request only what is needed to assess the case and prioritize the documents that can change the strategy.

3

Map

We separate urgency, risk, possible correction, and the negotiation or litigation scenario.

4

Execution

We prepare documents, responses or actions according to the chosen path.

Possible deliverables

What can be ready after the review.

The outcome depends on the case, but the consultation should result in concrete deliverables, not a loose opinion.

Route

An opinion on the course of action and priorities.

A clear map of urgency, documents, risks and alternatives to decide with less noise.

Documents

Response, contract, minutes, appeal or supporting document.

The review may conclude in legal instruments ready for signing, filing, negotiation or proceedings.

Estrategia

Negotiation, defense or legal action.

If the matter has already escalated, we define the path to talk, respond, claim, or defend.

Scope of the service

Topics we review in tax law.

These are the points that usually shape the strategy before responding, signing, negotiating, suing, or defending. The review starts from concrete facts and documents in order to choose a prudent path.

01

Situations we can review.

Common matters that are best read alongside documents, timelines, and real consequences.

Defense before the DIAN

Notices, summons, tax assessments, penalties, appeals, and tax litigation proceedings.

Tax planning

Corporate, asset, or contractual decisions that can change the tax burden.

Refunds and balances

Accounting and bank records, invoicing, payments, filings and traceability.

Directors' liability

Liability for tax decisions, beneficial owners, relevant transactions, and recordkeeping.

02

Documents worth preparing.

Not all are needed from day one, but they help organize the consultation.

  • Notices, official acts, returns, receipts, and prior responses.
  • Contracts, invoicing, accounting and bank records.
  • Corporate structure, beneficial owners, and relevant transactions.
  • Timeline of deadlines, notifications, payments and remedies.
03

Possible paths after the review.

The strategy depends on the evidence, deadline, opposing party, authority and objective.

  • Assess exposure, deadlines, and available tax evidence.
  • Prepare a response, appeal, lawsuit or correction if appropriate.
  • Coordinate the tax strategy with corporate, asset, and accounting matters.
04

Frequently asked questions about this service.

Initial responses to understand scope, documents and possible paths.

01What does a tax lawyer do in Colombia?

A tax lawyer advises on all fiscal obligations and designs the taxpayer's tax planning. At Cafore Abogados we specialize in tax and fiscal law with comprehensive advice on compliance, planning and litigation. We ensure compliance with fiscal obligations through a clear interpretation of the applicable tax laws and regulations. We provide advice on direct taxes —income, the supplementary occasional gains tax, wealth tax—, indirect taxes —VAT, the national consumption tax (INC)— and territorial taxes —industry and commerce tax (ICA), property tax. Planning is aimed at minimizing the tax burden within the legal framework, identifying benefits, exemptions, deductions and fiscal treatments applicable to the client's specific operation.

02How is a DIAN demand or official assessment handled?

In the face of an ordinary demand, special demand, summons or official assessment from the DIAN, the deadline to respond is peremptory and the quality of the reply conditions the entire proceeding. At Cafore Abogados we analyze the action, identify procedural defects, assess the evidence submitted and build the response within the legal deadline set by the Tax Statute (Decree 624 of 1989) and the Administrative Procedure Code. If the action ends in a sanction or assessment, we appeal at the governmental level through reconsideration and, subsequently, before the administrative litigation jurisdiction by means of an action for annulment and restoration of rights. Timely technical defense prevents forced collection and substantially reduces economic exposure.

03What does tax planning for companies include?

Corporate tax planning covers the design of the corporate structure, operations and specific transactions. At Cafore Abogados we provide advice on the fiscal structuring of commercial and financial transactions, fiscal efficiency through solid corporate structures and thorough fiscal reviews that identify savings opportunities and risk minimization. We analyze sector-specific tax benefits, free trade zones and special regimes, dividend planning mechanisms, the deduction of payments abroad, transfer pricing and the regime of controlled foreign entities (ECE). The goal is fiscal efficiency within the legal framework, never outside of it.

04Do you advise on international taxation and cross-border operations?

Yes. We are experts in international taxation: planning of cross-border operations, analysis of international tax treaties (Conventions to Avoid Double Taxation in force for Colombia with countries such as Spain, Canada, Mexico, Chile, Switzerland, the United Kingdom, France and others), management of global fiscal risks, tax residence, withholding at source on payments abroad, capital gains of non-residents, the regime of controlled foreign entities (ECE) and foreign-exchange and tax reporting obligations. Our team is equipped to resolve complex fiscal matters at the national and international level, helping our clients manage their obligations across multiple jurisdictions.

05How is tax litigation defended before the administrative litigation jurisdiction?

Tax litigation unfolds in two venues. At the governmental level, a reconsideration appeal is filed before the DIAN within two months following notification, seeking to revoke or modify the action. Once this avenue is exhausted, recourse is taken to the administrative litigation jurisdiction through the action for annulment and restoration of rights before the administrative courts or the Council of State, depending on the amount, in accordance with Law 1437 of 2011. At Cafore Abogados we have extensive experience in resolving tax disputes, using solid strategies in negotiations, administrative appeals and judicial proceedings, focused on obtaining favorable outcomes in fiscal disputes of any kind.

Related reading

Useful readings before making a decision.

These guides expand on legal topics related to the service and help you prepare better for the consultation.

Flag of Colombia in an article on asset protectionGestión patrimonial

Legal strategies to protect your assets in Colombia.

Strategies to protect family and business assets before a dispute or succession.

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Personas estrechando manos sobre una mesa con documentos legalesCorporate Law

Key aspects of corporate law in Bogotá.

A guide for companies that need to organize contracts, governance, risks and growth with legal support.

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Documentos legales con tableta, balanza y mazo judicialCommercial law

Commercial companies and contracts in Colombia.

How commercial companies are structured and what risks are worth reviewing before partnering or contracting.

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Imagen editorial sobre patrimonio familiarFamily estate

Organizing family wealth: a basic guide.

A basic guide to organizing assets, responsibilities, and decisions about your estate.

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Illustration of a lawyer who specializes in estate and asset lawEstate

The importance of having a lawyer who specializes in estate and asset law.

Why estate planning needs legal judgment, not just documents.

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Frequently asked questions

Real questions before consulting in tax law.

The answers are general. The specific decision depends on the documents, evidence, timelines and circumstances of the case.

Before your consultation

When is it advisable to consult in tax law?+
It is advisable to consult when a tax decision, assessment, penalty, refund, or asset reorganization needs legal defense and supporting documents. The first review prevents acting on impulse and helps organize documents, deadlines, and risks.
Do I have to come with all the documents?+
No. It is better to come with what is available and a brief chronology. Afterward, whatever is needed is requested according to the route.
Does the consultation always end in a proceeding?+
No. Sometimes the best way out is to correct, negotiate or prepare a response. A proceeding is an option, not an automatic destination.
What makes an early review different?+
It makes it possible to preserve evidence, measure timelines and avoid communications or signatures that later weaken your position.

Evidence and supporting documents

What documents should I prepare?+
As a baseline: assessments, official acts, returns, receipts and prior responses, contracts, invoicing, accounting and banking records, and corporate structure, beneficiaries, and relevant transactions. If something is missing, it is identified without forcing risky reconstructions.
Do emails, chats or screenshots work?+
They can help, but they must be organized by date, author, context and connection to the fact you want to prove.
What happens if the other party has the documents?+
We review how to request them, what indirect evidence exists and whether it is advisable to use formal requests, conciliation, inspection or procedural measures.
Should I send communications before consulting?+
If there is an urgent deadline, it may be necessary. But in sensitive cases it is advisable to review the message before leaving a written version.

Course of action

How is the course of action decided?+
We review facts, documents, urgency, cost, evidence, and objective. In this area, paths such as gauging deadlines and contingencies, organizing tax evidence, and preparing a response, appeal, or claim often arise.
When is it advisable to negotiate?+
When there is a real margin for agreement, solid evidence and an outcome that is faster or less costly than litigation.
When is it advisable to escalate?+
When there is urgency, bad faith, a risk of losing evidence, deadlines running, or a refusal that no longer allows an informal solution.
Can I change strategy later?+
Yes. The strategy must be adjusted when new documents, responses from the other party or decisions by the authority emerge.

Costs, timelines and scope

How long does a first review take?+
It depends on the volume of documents and the urgency. The first conversation aims to define the scope and the relevant documents.
Does the advisory service include drafting documents?+
It may include them if the case requires it: notices, contracts, minutes, replies, appeals, lawsuits or agreements.
Can I consult even if I do not want to sue yet?+
Yes. In fact, many good outcomes begin before deciding whether to sue.
What if I want to study the topic before consulting?+
You may review the related readings to understand general concepts, but the specific decision must be made with the documents, deadlines and facts of the case.

Next step

Tell us what decision, dispute or document you need to review.

You don't have to arrive with everything organized. The first review serves to identify which documents matter and which legal path makes sense.

Schedule a consultation