Colombia's National Tax Authority (DIAN) recently issued a ruling that clarifies the deduction restrictions for overseas payments. Under domestic law, the deduction of overseas payments is generally limited to 15% of net income if the payments have not been subject to withholding tax and certain other cases. According to the ruling, however, the deduction restriction does not apply if a payment to a foreign recipient is not subject to withholding tax due to the provisions of an applicable tax…