Colombia Clarifies that Payments for Legal Services Treated as Royalties under Tax Treaty with Spain

Colombia's National tax Authority (Dian) recently issued Ruling 5945 of 2016, which clarifies the tax treatment of payments for legal services under the 2005 income and capital tax treaty with Spain. Under Article 12 (Royalties) of the treaty, the definition of royalties includes payments for technical assistance, technical services and consulting services, while the protocol to the treaty also…
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