Colombia Clarifies Indirect Transfer of Branch in Free Trade Zone Not Eligible for Preferential Rate

The Colombian tax authority (DIAN) recently released Ruling 7858 int 924 of 18 June 2025, which clarifies the taxation of an indirect transfer of a branch established in a Free Trade Zone. The ruling clarifies that when a non-resident shareholder sells shares in a foreign company that owns a Colombian branch, the transaction is taxed in Colombia under the Indirect Disposal Regime (REI). When a…
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