OrbitaxOrbitax

Council of State of Colombia Upholds Tax Authority Ruling that Royalties MFN Clauses Not Triggered in Tax Treaties with Chile, Spain, and Switzerland

|Treaty Development|Colombia-Chile-Spain-Switzerland
Colombia-Chile-Spain-Switzerland

The Council of State of Colombia, which is the highest court for tax matters, issued a decision on 4 April 2024 concerning a tax authority ruling on the activation of the MFN clauses in Colombia's tax treaties with Chile, Spain, and Switzerland.

As previously reported, the Colombian tax authority (DIAN) issued a ruling in February 2020 that clarified the impact of the 2016 income and capital…

Continue Reading