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Fluctuations in assets and liabilities held in foreign currencies would have tax effects only after the asset is disposed or the liability is totally or partially paid.

Income, costs, expenses, assets and liabilities held in foreign currencies would be measured at the foreign exchange benchmark rate determined by the Colombian Central Bank, applicable at the moment of the initial recognition.

Any gain derived from the difference between (i) the foreign exchange benchmark rate applicable at the moment of the initial recognition and (ii) the foreign exchange benchmark rate at the moment of the disbursement of the payment will be taxed either as short- or long-term capital gain.