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DIAN REVENUE RULING

Periodic application of Legal Stability Agreements

DIAN Revenue Ruling No. 02573 of February 15th, 2016

 

In its revenue ruling, the Colombian Tax Authority (DIAN) clarifies that when a Legal Stability Agreement is signed within a particular income tax period, the rules applicable to the tax period in which the Agreement was subscribed are not those defined in the Agreement, considering that at the time in which the period started, there was still no contractual relationship.

However, for purposes of complying with the complete term of the Legal Stability Agreement, the last taxable period for which it will be in effect, shall be the end the contractual relationship, for all year. To this extent, even if the termination date of the Agreement does not necessarily coincide with December 31st (the day in which the taxable year ends), the Agreement shall be valid until such date.