As part of Colombia's tax reform plans for 2017 ({News-2016-10-25/P/2- previous coverage}), a number of measures have been proposed based on the OECD BEPS project. The measures include:

• The introduction of controlled foreign company (CFC) rules (Action 3) that would require taxpayers with a 10% or greater direct or indirect holdings in a CFC to include their pro-rata share of the CFC's passive…