EYColombia's highest tax court sustains tax authority opinion denying activation of most-favored-nation clause in double tax treaties
|Tax Alerts, Legislation & Policy, Na ...|Colombia
The Council of State — Colombia's highest tax court — has declined to annul a Colombian tax authority opinion ruling that three double-tax treaties (DTTs) Colombia had executed were not affected by provisions in a later-executed DTT, because most-favored-nation clauses (MFNCs) in the three DTTs were not activated.
The 4 April 2024 decision (file number 25411) reviewed the Colombian tax authority's …
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