In a ruling issued on 20 March 2014, Columbia's National Tax Authority clarified when deemed minimum interest on loans between related parties is applied and when related party loans are exempt.
Under Colombia's tax law, loans provided by a company to a partner or shareholder or vice versa will generate a deemed minimum interest rate based on the term of the loan and the fixed term deposit rate in force in Colombia on 31 December of the year immediately prior to the taxable year.
However, …