Colombia–MNE Tax

Colombia

The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).

July 5, 2022

According to Resolution 37 from March 17, 2022, DIAN modified articles 4, 10, and 13 of 2021’s Resolution 164, which provided administrative regulation to articles 631-5 and 631-6 of the Colombian National Tax Statute (ET).

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

February 22, 2022

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

Americas

Netherlands, Colombia sign income tax treaty: Geis / Commentary Box Sports→

February 18, 2022

Americas

Colombian regulation addresses ultimate beneficial owner report for tax purposes

January 18, 2022

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian tax administration’s implementation of a regulation on the registration of the ultimate beneficial owner-report for tax purposes, which entered into force on January 15, and establishes . . .

Africa

‘Tax Inspectors Without Borders’ expands developing country tax and transfer pricing assistance

November 9, 2021

Tax Inspectors Without Borders – a joint initiative of the OECD and United Nations Development Programme – expanded the scope of its assistance to developing country tax administrations, according to the initiative’s 2021 annual report released November 9, amid challenges faced by . . .

Americas

Colombia approves tax reform with corporate rate increase, numerous changes

September 22, 2021

María Helena Padilla, González y Prieto Abogados, discusses the Colombian Congress’s September 9 approval of the social investment law with tax measures to fund new social programs, including an increase in the corporate . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Americas

Colombian tax reform proposes corporate rate increase, tax avoidance measures

August 10, 2021

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian government’s introduction of a tax reform bill on July 20 that includes an increase in the corporate tax rate, new measures to . . .

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Americas

Costa Rica joins OECD

May 26, 2021

The OECD officially welcomed Costa Rica as its 38th member country on May 25 after it completed the process for ratification of the OECD convention and deposited its instrument of accession . . .

Asia-Pacific

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

May 11, 2021

Ritu Shaktawat and Rahul Jain, Khaitan & Co., discuss the High Court of Delhi’s April 22 ruling in a landmark judgment concerning the interpretation of the India-Netherlands tax treaty’s most favored nation clause . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

Colombia clarifies commodities registration rules for transfer pricing as deadlines approach

November 5, 2020

Laura Pinilla, an Associate at BaseFirma, Colombia, discusses guidance recently released by the Colombian tax office that further clarifies new rules requiring taxpayers subject to the transfer pricing regime to register commodities agreements . . .

Americas

Colombia publishes MAP guidance for resolution of tax treaty disputes

October 15, 2020

Juana Obando, Transfer Pricing Associate at BaseFirma Colombia, discusses August 21 Colombian tax authority guidance on the procedure to request the resolution of cross-border tax disputes under Colombia’s tax treaties . . .

Americas

Colombia publishes new guidance on the tax incentive for mega-investments

September 4, 2020

Cindy Simbaqueva, a transfer pricing manager at BaseFirma Colombia, Bogotá, discusses August 21 guidance published by the Colombian tax authority on Colombia’s mega-investment tax incentive . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

Colombian tax office launches new platform allowing registration of commodities agreements for transfer pricing purposes

August 24, 2020

Laura Pinilla, an associate with BaseFirma Colombia, discusses a form released August 3 by the Colombian tax office, which is part of a new platform requiring taxpayers subject to the transfer pricing regime to register agreements related to transactions that involve commodities . . .

Americas

Colombia publishes guidance on taxation of indirect transfers

August 24, 2020

Cindy Simbaqueva, a transfer pricing manager at BaseFirma Colombia, Bogotá discusses August 10 guidance issued by the Colombian tax authority related to the taxation of indirect transfers . . .

Americas

Colombia officially joins OECD as 37th member: Modern Diplomacy→

May 4, 2020

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

OECD releases transfer pricing country profiles for Chile, Finland, Italy; updates Colombia, Israel profiles

June 18, 2019

The OECD today released new transfer pricing country profiles for . . .

Americas

Colombia tax reform expected to include rate reduction, thin cap change, new rules for financial transactions: EY→

October 29, 2018

Americas

Colombia clarifies that dividend tax won’t apply to dividends paid from pre-FY 2017 profits: EY→

March 14, 2019

Africa

Twenty nations’ tax laws may aid multinational profit shifting, OECD report says

October 17, 2017

Twenty countries have tax laws that may be considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Japan, Colombia agree to sign tax treaty

December 21, 2017

The governments of Japan and Colombia have agreed in principle on the terms of a tax treaty, Japan’s Ministry . . .

Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Africa

Paper reviews findings of 9 academics on likely impact of BEPS anti-hybrid rules on Uruguay, Colombia, Brazil, South Africa: SSRN→

March 29, 2017

See: SSRN.

Americas

US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives

December 19, 2016

The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .

Americas

OECD asks MNEs for feedback on cross-border tax dispute resolution in Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania, South Africa

July 26, 2018

The OECD is seeking feedback on multinationals’ experience with cross-border tax dispute resolution procedures in . . .

Americas

Japan, Colombia to commence tax treaty negotiations

December 4, 2017

The governments of Japan and Colombia will initiate negotiations for a tax convention between the two countries, Japan’s Ministry of Finance announced today. The Ministry said the . . .

Americas

Proposed Colombia tax law overhaul includes corporate tax simplification, increases to tax base, adds dividend withholding tax: KPMG→

October 24, 2016

See: KPMG.

Americas

Colombia clarifies country-by-country reporting obligation: EY→

May 11, 2017

Switzerland weighs expansion of automatic exchange of tax information to 20 more countries

February 2, 2017

Davide Anghileri of the University of Lausanne discusses Switzerland’s decision to launch a consultation on automatic exchange of information with 20 more countries . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin