Colombia's National Tax Authority (DIAN) recently issued Ruling 47390 of 2014 clarifying the tax treatment of losses, costs and expenses of foreign branches of Colombian companies. Key points of the ruling are summarized below.
- Tax losses of foreign branches are not deductible for tax purposes by the Colombian company, but may be carried forward indefinitely
- The deduction of costs and expenses incurred abroad attributed to a Colombian taxpayer's foreign branch is limited to 15% of the taxpay…