Colombia's National Tax Authority (DIAN) recently published a ruling on the taxation of commissions under the 2008 income and capital tax treaty with Canada. In prior rulings, DIAN had determined the income not specifically covered by the treaty, such as commission income, should be taxable in Colombia as per Article 20 (Other Income). In the latest ruling, however, DIAN determined that commission income should be considered business profits and, as per Article 7 (Business Profits), should on…