Colombia's National Tax Authority (DIAN) recently published Ruling 9164 (2015), which clarifies whether a non-resident is subject to net worth tax. According to the Ruling, a non-resident with net worth in Colombia exceeding COP 1 billion is subject to net worth tax whether held directly or indirectly through branches or permanent establishments located in Colombia.
As per Colombia's Tax Reform Act (Act 1739), passed the end of 2014, that rate of net worth tax from 1 January 2015 depends on…