The Colombian Tax Authority (DIAN) recently published a ruling clarifying the application of the country's CFC regime. The regime is effective from 1 January 2017 and provides for the inclusion of the pro-rata share of passive income of a CFC in the taxable income of Colombian tax residents, including both individuals and companies. Some of the key points include:
- A company is considered a CFC if the company is not tax resident in Colombia and the company is controlled by one or more persons…