The Colombian tax authority (DIAN) recently issued Ruling 466 of 21 June 2024, which concerns the concept of beneficial ownership for royalty payments under the 2018 tax treaty with Italy. In particular, the ruling addresses the payment of royalties by a resident of Colombia to a resident of Italy that acts as an agent or representative of natural persons to whom the royalties will be subsequently transferred. The ruling clarifies that in such cases, the natural persons must be considered the…