Colombia's National Tax Authority (DIAN) recently published a ruling on the taxation of "other income" as covered under Article 20 of the 2008 income and capital tax treaty with Canada. Article 20 (Other Income) includes that items of income not dealt with in other articles of the treaty that arise from sources in a Contracting State may be taxed by that State. Article 20 provides no other provisions for the taxation of "other income" aside from a 15% tax rate limit applicable in Canada on in…