Colombian Tax Authority Clarifies CFC Exemption for Income from Real Economic Activity

The Colombian Tax Authority (DIAN) recently published a ruling concerning whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a CFC in Colombia. The situation involved a Colombian resident that held two CFCs that each held a share of another company operating in Colom…
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