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Category: Tax Matters

Colombian Tax Ruling on Loan Transactions with Independent Third Parties

November 29, 2024

New ruling states that all loan transactions will be treated as taking place between related parties unless proven otherwise.  Recently, the Colombian tax authority (DIAN) ratified the requirement of a certification for loan transactions, to determine whether the transaction involves related parties. 

New Administrative Guidance from the OECD/G20 Inclusive Framework on BEPS

June 24, 2024

This new OECD publication provides new administrative guidance to support the practical application of the GloBE rules. Recapture Rule: guidance on the application of the recapture rule for deferred tax liabilities. Deferred Tax Assets and Liabilities: clarification on determining deferred tax assets

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