In a recent ruling, Colombia's Tax Authority (DIAN) clarified the obligation of a non-resident to file a tax return for income that is exempt under a tax treaty. According to the ruling, when a resident of a treaty partner derives Colombian-source income that is exempt from Colombian tax under the provisions of the treaty, the obligation to file a tax return still applies if the non-resident would otherwise be obligated to file a return under Colombian law. This generally includes when the ap…