The DIAN, through Ruling 0158 of January 26, 2026, expressly amended its interpretation regarding the Supporting Document for purchases from parties not required to issue invoices (DSNO), introducing a more favorable criterion for taxpayers.
What was the previous position?
Until this ruling, the DIAN held that if the DSNO was not generated and transmitted within the same taxable year in which the transaction took place, the cost or deduction could be rejected for tax purposes, even if the expense had actually occurred during that period.
This interpretation frequently created contingencies, especially for transactions carried out at year-end, where the supporting document was generated in the following period for operational or commercial reasons.
What changes with Ruling 0158 of 2026?
With this new ruling, the DIAN reconsiders its position and clarifies that:
Costs and deductions may be accepted in the year in which the transaction occurred, even if the DSNO is generated the following year, provided it can be shown that the expense was genuine and actually took place during that period.
To reach this conclusion, the DIAN acknowledges that the DSNO serves an evidentiary function equivalent to that of a sales invoice or equivalent document, and that paragraph 2 of Article 771-2 of the Tax Code also applies to this type of document.
Basis for the change
The agency bases its new interpretation on:
- The principle of economic substance.
- The purpose of paragraph 2 of Article 771-2 of the Tax Code, created to prevent tax rejections due to timing differences between the transaction and the supporting document.
- The functional equivalence between the sales invoice and the DSNO as valid mechanisms for supporting costs and deductions.
All of the above without disregarding the formal obligations to generate and transmit the DSNO.
What does this mean for companies?
This change:
- Reduces the risk of costs and deductions being rejected for purely formal reasons.
- Provides greater legal certainty in audit processes.
- Facilitates the handling of transactions carried out at the close of the taxable year.
- Reinforces the importance of keeping supporting evidence of the actual expense, even when the document is issued later.
Practical recommendation
Although this ruling makes the tax treatment more flexible, it is essential for companies to:
- Keep sufficient evidence demonstrating the reality and timing of the expense.
- Promptly regularize the generation and transmission of the DSNO.
- Review their internal processes to minimize formal contingencies.