The Colombian Tax Authority (DIAN) recently published a ruling concerning whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a CFC in Colombia. The situation involved a Colombian resident that held two CFCs that each held a share of another company operating in Colombia.
Under Colombia's CFC rules, income of a CFC held by a Colombian resident may be exempt from t…