DIAN REVENUE RULING
Comprehensive Revenue Ruling for the Controlled Foreign Corporations Regime (“CFC”)
The Tax Authority issued a unified revenue ruling resolving doubts regarding the CFC Regime
By means of Revenue Ruling No. 9193 of April 10the 2018, the Tax Authority issued its comments with regards to the definitions of the CFC’s, as foreign entities controlled by Colombian tax residents, the application of the regime, the taxpayers subject to the regime and the determination and allocation of passive income.
Furthermore, the Tax Authority referred to the treatment that taxes paid by the CFC should have upon the effective distribution of dividends by the CFC.