The Colombian Tax Office (DIAN) issued the Tax Ruling No. 305[008717] of 30 April 2024, interpreting several matters regarding the application of the Significant Economic Presence rules. The following are the most relevant points addressed by the Ruling:
• Cases in which the deduction for payments abroad related to SEP transactions are not capped under article 122 of the Tax Code.
• Identification of SEP taxpayers that have opted for the filing/no WHT mechanism and those who are not subject to the regime.
• Scope of the activities that can be considered taxed under SEP rules.
• Comments on the priority order rules of withholding agents.
The OECD has provided further updates on its Pillar 2 initiative and some countries have responded with their intention to implement as early as 2024. In this episode, Ciro Meza, Miles Humphrey, and Allen Tan highlight key points of the new guidelines, questions that companies have been raising and how these may affect TMT companies. Since the impact of Pillar 2 will transcend various functions within a business, Baker McKenzie experts will share their insights on how TMT companies should react to these developments and when they should start taking action in light of the implementation timelines that have been announced.
Law 2068, which modifies the general tourism regime in Colombia, was published on 31 December 2020. The law’s main objectives are to promote sustainability; implement mechanisms for the conservation, protection and use of different tourist attractions; increase competitiveness; and promote the recovery of Colombian tourism through the creation of different incentives.
Baker McKenzie’s VAT/Indirect Tax Practice presented ‘Digital Services in Latin America,’ on 12 August 2020. This was the second presentation in the International VAT Conference Webinar Series, a global webinar series designed for VAT specialists from all industry sectors that aims to discuss the latest developing trends and hot…
Baker McKenzie’s VAT/Indirect Tax Practice presented ‘Digital Services in Latin America,’ on 12 August 2020. This was the second presentation in the International VAT Conference Webinar Series, a global webinar series designed for VAT specialists from all industry sectors that aims to discuss the latest developing trends and hot topics in the VAT/GST and customs arena.