On 25 June 2014, the Colombia tax authority (DIAN) issued a ruling on the application of withholding tax on payments made to foreign portfolio investors. The key aspects of the ruling are as follows.
The ruling states that tax withheld on payments to foreign portfolio investors is not considered an advance tax payment and income tax liability of the foreign investor and must be paid in full. The administrator of the portfolio investment must withhold tax at a rate of 14%, or 25% if the inves…