The Colombian tax authority (DIAN) has issued Ruling 305 of 30 April 2024, which addresses several questions concerning the new rules for non-residents with a significant economic presence (SEP) in Colombia. One of the key questions concerns the restriction on the deduction of foreign costs and expenses under Article 122 of the Tax Statute in cases where payments are made to a non-resident with an SEP in Colombia that has opted to file a tax return in Colombia. The Ruling explains that taxpay…