The Colombian tax authority (DIAN) has published Resolution No. 000085 of 21 August 2020, which establishes rules for taxpayers to request access to the Mutual Agreement Procedure (MAP) under Colombia's tax treaties. The rules are effective from 27 August 2020.
The resolution provides that when a Taxpayer considers that the actions of one or both Contracting States to a tax treaty has resulted or will result in taxation not in accordance with the provisions of the treaty, the taxpayer may r…