Colombian Tax Authority clarifies profits distributed by Colombian branch to its home office in Spain are not dividends

The Colombian Tax Authority issued Official Tax Opinion No. 370 of 2020, which clarifies that profits distributed from a Colombian branch to its home office in Spain should not be considered “dividends” under the tax treaty between Colombia and Spain. Instead, such distribution should be considered a “business profit,” covered by Article 7 of the tax treaty, and generally not subject to taxat…
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