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Daniel Octavio Morales Velásquez

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Daniel is a lawyer from Universidad Externado de Colombia, with a specialization in corporate tax law and business law from the same university. He is a specialist in taxation from Universidad de los Andes and is currently studying a Master's degree in taxation at the same university.
During his career he has advised national and international clients in consulting matters for the development of operations in Colombia and abroad, as well as in administrative and judicial litigation on national and municipal taxes.

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.