Colombia's National Tax Authority (DIAN) recently issued a ruling concerning the availability of benefits under the 2005 tax treaty with Spain for dividends paid out of untaxed profits. Under Colombia's domestic withholding tax rules, dividends paid out of untaxed profits to a non-resident are subject to a 33% withholding tax. If the profits have been taxed, no tax is withheld. According to the ruling, the same applies under the treaty. However, based on the provisions concerning Article 10 (…