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

|Approved Changes|Colombia
Colombia

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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