14Years November 16 , 2018, yr. 14 – Nolewinywills.com/.../11/Colombian-Tax-Flash-2018-Tax... · 1.2. New Colombian Holding Company (“CHC”) Regime The Tax Reform Bill proposes

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14Years November 16th, 2018, yr. 14 – No.31

By: Cristina Stiefken ([email protected]), Gustavo Peralta

([email protected]) and Federico Lewin ([email protected])

NEW TAX REFORM BILL INTRODUCED TO CONGRESS

On October 31st, 2018 the Colombian Government introduced a new Tax Bill to Congress. In this issue, Colombian_Tax_Flash® summarizes the main changes proposed in the 2018 Tax Bill, in connection with: (1) CORPORATE INCOME TAX: (1.1) Rate Reduction; (1.2) New Colombian Holding Companies Regime (1.3) Dividend Taxation; (1.4) Withholding Tax on Cross-Border Payments; (1.5) Permanent Establishment (“PE”) Worldwide Taxation; (1.6) Corporate Income Tax Assessment; (1.7) Special Tax Regimes; (2) ANTI-ABUSE PROVISIONS: (2.1) Taxing Indirect Sales; (2.2) Collective Investment Vehicles; (2.3) Attestation in the Sale of Immovable Property; (3) VAT: (3.1) VAT Rate Reduction; (3.2) Broadened Scope of Transactions Taxable with VAT; (3.3) Income Tax Credit of VAT paid in the Production, Acquisition or Import of Capital Assets; (4) TAXES ON CAPITAL: (4.1) Net-Equity Tax; (4.2) Repeal of the Alternate Minimum Taxable Income; (5) NEW REGULARIZATION FACILITY; (6) SIMPLE TAX; (7) OTHER PROVISIONS RELEVANT FOR RESIDENT INDIVIDUALS. 1. CORPORATE INCOME TAX 1.1. Rate Reduction The Tax Reform Bill proposes reducing the Corporate Income Tax (“CIT”) rate, without renewing the CIT Surcharge that under current regulation is in place until this year; the proposed reduction would operate as follows

Currently 2019 2020 2021 2022 33% + 4% 33% 32% 31% 30%

Nonetheless, please bear in mind that certain types of entities (e.g. small and medium enterprises subject to Act 1429/2010) and certain types of activities (e.g. companies that manage Pension Funds and editorials) that are currently subject to a reduced 9% CIT rate would, as of 2019, be subject to the general CIT rate, referred to herein above. Income from hotel services rendered in newly built and refurbished facilities would continue to be subject to the reduced 9% CIT rate.

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1.2. New Colombian Holding Company (“CHC”) Regime The Tax Reform Bill proposes introducing a new regime, for Colombian Holding Companies (“CHC”) dedicated to investing in shares of foreign companies and securities and the management of such investments may opt-in for the CHC Regime, provided that they meet the following requirements: (a) Minimum Holding Requirement: The CHC shall have, directly or indirectly,

held at least a 10% stake in the capital of the foreign companies, for at least a 12-month period.

(b) Minimum Economic Substance Requirement: The CHC shall have at least

3 employees, an address in Colombia (belonging to the CHC, not to a third party), and shall be able to prove that the strategic decisions in connection with the investments and assets of the CHC are taken in Colombia (please note that only carrying out the Shareholders’ meetings in Colombia is not enough to meet this requirement).

In the following tables we summarize the main tax benefits (i) for the shareholders of a CHC, and (ii) for a Colombian company subject to the CHC Regime:

Tax Benefits for the Shareholders of the CHC Colombian Tax Resident Foreign Tax Resident CHC distributes dividends to

Taxed in Colombia, with right to a Foreign Tax Credit on any tax paid abroad by the company that distributed dividends to the CHC.

Exempt from Dividends Tax in Colombia, provided that the income out of which the dividends were distributed (i) is attributable to activities carried out by foreign entities; (ii) is not covered by the Colombian Controlled Foreign Entities Regime; and (iii) the shareholder is neither resident in a non cooperative jurisdiction, nor subject to a preferential tax regime.

Sale of the shares of the CHC by

Exempt from Capital Gains Tax and CIT in Colombia, provided that (i) the price received in consideration for the shares is attributable to

Exempt from Capital Gains Tax and CIT in Colombia, provided that (i) the price received in consideration for the shares is attributable to value created by

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value created by foreign entities 1 ; and (ii) the company from which the CHC is selling the shares does not qualify as a Colombian Controlled Foreign Entity.

foreign entities1; (ii) the company from which the CHC is selling the shares does not qualify as a Colombian Controlled Foreign Entity; and (iii) the shareholder is neither resident in a non-cooperative jurisdiction, nor subject to a preferential tax regime.

Tax Benefits for the Company Subject to the CHC Regime

Colombian Company Foreign Company Dividends received by the CHC from

Taxable in Colombia, subject to both Dividends Tax and CIT.

Exempt from CIT in Colombia, provided that the income out of which the dividends were distributed (i) is attributable to activities carried out by foreign entities; and (ii) is not covered by the Colombian Controlled Foreign Entities Regime.

CHC sells its shares in a

Taxable in Colombia, under the Capital Gains Tax or CIT, as applicable, depending on the circumstances.

Exempt from Capital Gains Tax and CIT in Colombia, provided that the income out of which the dividends were distributed (i) is attributable to activities carried out by foreign entities; and (ii) is not covered by the Colombian Controlled Foreign Entities Regime.

1.3. Dividend Taxation The Tax Reform Bill is proposing two changes to dividend taxation: Firstly, dividends proceeding from profits that were not taxed at the corporate level, distributed to individuals that are Colombian tax residents would be taxed at the rate applicable to legal entities (33% in 2019, 32% in 2020, 31% in 2021 and 30% as of 2022). Currently the applicable rate is 35%. Secondly, dividend tax would apply to Colombian companies receiving dividends, even if the profits out of which the dividend is distributed were already taxed at the level of the distributing company. The dividends tax rate

1 The amount of profits generated as a consequence of activities carried out in Colombia by the CHC is considered as value not created by the foreign entity, and is therefore not covered by the Capital Gains Tax/CIT exemption.

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would be 5%. This tax would be caused only at the first dividend distribution, and the tax credit would be transferred until the last beneficiary of the dividends (individual). 1.4. Withholding Tax on Cross-Border Payments In the following table we summarize the main changes proposed in connection with the withholding tax rates on cross-border payments:

Payment Previous rate New rate Interest from loans with a term shorter than 1 year, Commissions, fees, royalties (except for royalties on software), leases, as well as any other payment made in consideration for personal services

15% 20%

Royalties on software. 26,4% 20% Consultancy services, technical services and technical assistance

15% 20%

Management fees, royalties and any other fees in connection with the use of intangibles paid by Colombian entities to their home office

15% 33%

1.5. Permanent Establishment (“PE”) Worldwide Taxation The Tax Reform Bill proposes that PEs be taxed on their attributable income regardless of the source. This implies a change to the current rule, introduced by the 2012 Tax Reform Act, according to which PEs are taxed for CIT purposes on their Colombian sourced attributable income. Therefore, if part of the income attributable to the PE is not Colombian sourced, under current regulations, it would not be taxable for CIT purposes. It is worth highlighting that the current treatment is different from the general rule by virtue of which PEs are taxed on the income that is attributable to them regardless of the source of the income. 1.6. Corporate Income Tax Assessment In the following subsections we summarize some major changes with regards to the assessment of CIT proposed by the Tax Reform Bill: 1.6.1. Corporate Income Tax Deductions The Tax Reform Bill explicitly states that, with the exception of CIT, the taxes and other levies paid by Colombian taxpayers are fully deductible, provided that

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there is a nexus between the payment and the income producing activity carried out by the taxpayer, solving various disputes that have arisen in recent years between the taxpayers and the Tax Authorities on this matter. 1.6.2. Items of Foreign Source Repealed The Tax Reform Bill proposes repealing the provision, according to which interest payments in connection with cross-border financing facilities aimed at funding and pre-funding of exports are deemed foreign source income and are, thus, not taxed in Colombia. If approved, this change would imply that such interest payments would be subject to withholding tax at a 20% or 15% rate, depending on the term of the credit facility. 1.6.3. Exempt (non-taxable) Items of Income Repealed The Tax Reform Bill proposes repealing the exemption of many items of income. Some of the exemptions that are currently in place and would be repealed (treated as taxable items of income) if the Tax Reform is enacted are (i) fluvial transportation services using low draught boats; (ii) Pension Funds’ income and (iii) exploitation of qualified forestry plantations. 1.6.4. Creditable VAT, Turnover Tax and Bank Debits Tax One of the core principles of the 2019 Tax Reform Bill is to provide a relief in

the tax burden that businesses face. In this line, the following are some of the most powerful incentives included in Tax Reform Bill:

(a) Tax credit for value added tax (VAT) paid in the acquisition, import or

construction of fixed assets. In line with the idea of lowering taxes on businesses, Government has proposed a full tax credit against income

tax of the VAT paid in the acquisition, importation or construction of fixed assets. This is an important benefit for businesses because current

law only grants a deduction of the VAT paid in the acquisition or import

of capital assets. Hence, instead of recovering up to 33% of the VAT paid, under the proposed rule, businesses will recover 100% of the VAT paid in

the acquisition, import or construction of a fixed asset. Consequently, the VAT paid will not be considered as part of the asset’s cost for

depreciation purposes.

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(b) Tax credit for turnover tax (ICA) and Bank Debits tax paid. Pursuant to the current proposal, 50% of the ICA and Bank Debits taxes will be

creditable against the payable Income Tax liability. From 2022 onwards, the applicable rate of the tax credit will go up to 100%. Please note that

in this case, the taxpayer faces a choice whether to have the taxes deducted or as a tax credit.

1.6.5. Repeal of the Alternate Minimum Taxable Income As further explained in §4.2 below, the Tax Reform Bill suggests eliminating the obligation of the Colombian taxpayers to assess their CIT liability using the Alternate Minimum Taxable Income method, through a phase-out rate scale, as follows:

Currently 2019 2020 As of 2021 3,5% 3% 1,5% 0%

1.7. Special Tax Regimes 1.7.1. Mega-Investments The Tax Reform Bill establishes a special tax regime for any Income Tax taxpayer who generates at least 50 direct work places and makes new investments of at least 50,000,000 UVT (approx. COP 1,400,000 million or USD 441,140,000). This regime implies: (i) a reduced Income Tax rate of 27% (9% for any income derived from hotel services); (ii) a reduced 2-year depreciation term, (iii) exclusion of the obligation to assess the Income Tax liability using the Alternate Minimum Taxable Income; (iv) that dividend distributions would not levy Dividends Tax if originated in income taxed at the corporate level, and would be taxed at a reduced 27% Dividend Tax rate if the dividends are originated in income that was untaxed at the corporate level; and (v) projects qualified as Mega-Investments would be disregarded when assessing the Net-Equity Tax. This special regime would be applicable for a term of 20 years to investments made before 2024. The Tax Reform Bill proposes establishes that investments related to the evaluation and exploration of non-renewable natural resources, infrastructure projects and projects related to the construction and operation of free trade zones are not eligible as Mega-Investments. In order to enforce this regime, the Tax Reform Bill establishes legal stability contracts to be subscribed by the State and the investor. Through these

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contracts, the State guarantees that the above mentioned special tax conditions will be applicable for the investor throughout the term of the contract. In consideration for executing the stability contract, the investor would be obliged to pay, during the first 5 years, a premium of 0.75% of the value of the yearly investment. 1.7.2. Creative Industries One the government’s main policy proposal is related to the promotion of creative industries in Colombia; the so-called orange businesses. One of the ways in which government intends to do so is by creating a 5-year Income Tax exemption. In order for a company to qualify for this tax benefit it must:

1. Be incorporated and executing its business activity before December 31st, 2018.

2. Have its domicile in Colombia. 3. Be exclusively engaged in the development of a business activity

previously defined by government as a creative industry. Such industries include, but are not limited to, the following:

a. Clothes, furniture, jewelry manufacturing; b. Software development; c. Theatre and other cultural activities.

4. Employ at least 10 full time workers without considering the business administrators.

5. Develop a project, which must be approved by the Orange Business Committee of the Ministry of Culture.

6. Invest in a 3-year period at least USD 250,000 in the development of the orange business. If this threshold is not met, the Income Tax exemption will not be applicable from the third year onwards.

One key aspect of this regime is that in reality it only provides for an Income Tax deferral. This is because upon distribution of dividends from the companies benefited from the Income Tax exemption, a recapture mechanism will be triggered. Therefore, dividends distributed whose origin is income that was exempted from taxation will be subject to a 33% withholding tax and an additional 5% withholding tax, which corresponds to the tax on dividends. 2. ANTI-ABUSE PROVISIONS 2.1. Taxing Indirect Sales The Tax Reform Bill introduces a special anti-abuse provision aimed at taxing in Colombia indirect sales of shares and assets located in Colombia.

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Currently indirect sales of shares of Colombian companies and assets located in Colombia, via the sale of shares in a foreign holding company, are not taxable events in Colombia, due to the fact that under current regulation, the sale of shares of foreign companies generate foreign source income, even if all the assets owned by the foreign company whose shares are being sold are located in Colombia. 2.2. Collective Investment Vehicles (“CIVs”) CIVs, including private equity funds (“PEF”), in Colombia are deemed as disregarded entities for income tax purposes. Therefore, all the activities and investments performed by CIVs are taxed at the level of the investor, as if it had directly undertaken the activity. Currently, income must only be recognized upon distribution of profits from the CIV to its investors. In the case of PEFs, the distributions are first deemed to be a reimbursement of capital and once the capital has been fully reimbursed, any distribution will be taxed as profits. The Tax Reform Bill includes an anti-avoidance rule by virtue of which the deferral of income will only be achieved in the following three cases:

1. CIVs whose participation rights are listed in the Colombian Stock Exchange.

2. CIVs in which: a. No more than 20% of its participation rights are directly or

indirectly owned by the same beneficial owner or by members of the same family, that are subject to Colombian Income Tax; and,

b. None of the CIVs beneficial owners, either separately or jointly, has control over the CIV’s distribution of profits.

3. CIVs not constituted with the main purpose of serving as a vehicle for Income Tax deferral.

It is worth noting that profits that have been accrued in CIVs created before the new tax law comes into force will be subject to taxation in taxable year 2019, unless the CIV meets one of the requirements for income deferral just mentioned. In a similar line, the new tax law provides a new rule regarding the income tax withholding applicable to CIVs. Therefore, if the CIV is granted the deferral the withholding will only be applicable upon distribution of profits to its investors. In all other cases, the withholding will be performed by the administrator of the CIV depending on the nature of the income and the regime applicable to its beneficiary in the same fiscal year in which the income is received by the CIV.

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2.3. Attestation in the Sale of Immovable Property In order to strengthen measures against tax avoidance and tax abuse, the Tax Reform Bill establishes that the parties granting a public deed of sale of immovable property would be obliged to declare the truthfulness of the price included in such document. If this declaration is not included in the public deed: (i) the price, for tax purposes, would be deemed 4 times higher than the price set forth in the public deed; and (ii) the notary should report this irregularity to the Tax Administration. In addition, any amount paid for the acquisition of immovable property that is not disbursed trough financial entities would not constitute tax cost basis of such property for the buyer. It is also proposed that the persons involved in transactions with evasion or tax abuse purposes, would be jointly and severally liable for any tax, interests or penalties that the Tax Administration had not collected. The directors of vehicles used for evasion and tax abuse purposes will also be jointly and severally liable before the Tax Administration. 3. VAT 3.1 VAT Rate Reduction Currently the general VAT rate is 19%; a reduced 5% rate applies for certain goods and services and there are other goods and services that are either zero-rated (exempt) or not taxed with VAT (excluded). The Tax Reform Bill proposes eliminating the reduced 5% rate, and taxing at 19% most of the goods and services that nowadays are either not taxed or taxed at a reduced rate, coupled with a reduction of the general rate, that will start with an initial reduction to 18%, followed by a further reduction to 17%, as of 2021. Hence the general VAT rate would be reduced as follows:

Currently 2019 2020 As of 2021 19% 18% 18% 17%

3.2 Broadened Scope of Transactions Taxable with VAT According to the Tax Reform Bill, most of the goods and services currently untaxed and zero-rated would be taxed at the general VAT rate.

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Some (not all) of the goods that would be taxed if the Tax Reform Bill were enacted are the following: animals, vegetables, grains and other foods in general, electric energy, construction materials, among others. Some of the goods that would remain untaxed or zero-rated if the Tax Reform Bill is enacted are: medicines, gas, weapons to be used by the armed forces, goods sold to foreign trade companies (CIs), among others. Some (not all) services that would be taxed if the Tax Reform Bill were enacted are the following: cloud computing, hosting and other digital services, freight transport, reinsurance brokerage and services that are intermediate for the production of an excluded/exempt good. Some of the services that would remain untaxed or zero-rated if the Tax Reform Bill is enacted are: medical services, education and public services. 3.3 Income Tax Credit of VAT paid in the Production, Acquisition or Import of

Capital Assets As already explained in further detail in §1.6.4(a), the Tax Reform Bill is proposing a full tax credit of the VAT paid in the acquisition, importation or construction of capital assets against the Income Tax liability. This implies that instead of recovering only 33% of the VAT paid, under the proposed rule, businesses will be able to recover 100% of the VAT paid in the acquisition, import or construction of a capital asset. 4. TAXES ON CAPITAL 4.1. Net-Equity Tax The Tax Reform Bill presented to Congress introduces for 2019 and 2020 a Net-Equity Tax (“NET”). Contrary to past similar taxes, Colombian entities

(corporations and partnerships) will not be subject to this tax. Therefore,

individuals who are tax residents, individuals who are not tax residents and foreign entities that on January 1st, 2019 have a net-equity equal to or higher

than USD1 million, will be subject to the NET. The following graph resumes the taxpayers and which part of their net equity will be considered for NET

purposes.

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NET’s taxable base is determined by subtracting the taxpayer’s debts from its

equity. Additionally, NET taxpayers are allowed to subtract the following:

(a) In the case of individuals, the first USD149,000 of the value of the house

of residency of the taxpayer provided that it is taxable; and,

(b) The assets that are subject to the complementary regularization tax created for 2019.

In this NET the triggering event and the dates in which the obligation to pay the

tax arises are separated. Therefore, for NET taxpayers the NET base for 2020

may increase or decrease only by 25% of 2019’s inflation rate.

Depending on the NET’s base, the applicable rate will vary as follows:

From Until (not included) Rate

USD 1 million USD 1,6 million 0,5%

USD 1,6 million Onwards 1%

4.2. Repeal of the Alternate Minimum Taxable Income Nowadays, besides assessing their Income Tax liability based on their Net Taxable Income (i.e. income minus costs and deductions), Colombian taxpayers

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(both individuals and corporate entities) are obliged to assess their Income Tax liability based on the Alternate Minimum Taxable Income (“AMTI”). Currently, the taxpayer's AMTI is equal to the taxpayer's net-worth (i.e. all assets net of all liabilities and other allowable exclusions, e.g. shares in Colombian corporations) as of December 31st of the year immediately preceding the taxable year, multiplied by 3,5%. If the AMTI is greater than the Net Taxable Income, the taxpayer shall use the AMTI as taxable base, and the difference between these two items generates a carry-forward against the taxpayer's Net Taxable Income, which can be used within the following 5 taxable years. The Tax Reform Bill suggests eliminating the obligation of the Colombian taxpayers to assess their Income Tax liability using the AMTI, through a phase-out rate scale, as follows:

Currently 2019 2020 As of 2021 3,5% 3% 1,5% 0%

5. NEW REGULARIZATION FACILITY In the Tax Reform Bill presented to Congress, Government proposes a new Regularization Tax (“RT”). This is a new opportunity for taxpayers who by January 1st, 2019 have either omitted assets or included non-existent liabilities in their tax returns to regularize their tax status. Therefore, taxpayers who have properly filed their tax returns will not be subject to RT. The taxable base of RT depends on what the taxpayer is regularizing. In the case of undeclared assets, the taxable base will be either its acquisition cost or its fair market value, which may not be less than the acquisition cost. It is important to consider that if the taxpayer used tax structures with the sole purpose of having a low acquisition cost, such structures will be disregarded and the taxpayer willing to regularize its situation must declare the underlying assets. In the case of inexistent liabilities, the taxable base will be the value for which such inexistent liabilities were declared. It is worth noting that the new RT states that rights in foreign trusts, private interest foundations, cash value insurance contracts and other fiduciary vehicles must be declared for RT and income tax purposes as rights in a Colombian trust. Therefore, rights in such vehicles must consider the assets and liabilities held by the vehicle and must be declared independently. Regarding who must declare such rights, the answer will depend on whether the beneficiaries are conditioned or not. If the right to be considered as a beneficiary is not conditioned, then the beneficiary must comply with the formal

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duty just described. If there is a condition pending, then the settlor or insurance taker, as the case demands, must comply with the formal duty. Lastly, pursuant to Government’s proposal, the applicable rate of the RT will vary from 6.5% to 13%. The different treatment will depend on where the undeclared asset is held and if after it is subject to the RT it is invested in Colombia. If the undeclared asset is held abroad and it is not invested in Colombia or is invested for a period of less than 2 years, then the applicable rate will be 13%. If the undeclared asset is held abroad but it is invested in Colombia for 2 years or more, the taxable base will be reduced by half. Therefore, the effective rate will be 6.5%. 6. SIMPLE TAX In order to promote the formalization of enterprises the project proposes a new simplified tax (“SIMPLE tax”) for small and medium enterprises. This SIMPLE tax would replace the Income Tax, local Turnover Tax and the Consumption Tax for any individual or corporate person obtaining gross income higher than 1,400 UVT (approx. COP 46,418,400 or USD 14,630) and lower than 80,000 UVT (approx. COP 2,652,480,000 or USD 836,000) who opts-in. The SIMPLE Tax establishes fix rates applicable to the gross income. Such rates vary depending on the sector in which the enterprise operates, but in any case, the

maximum rate is 13.6%. 7. OTHER PROVISIONS RELEVANT FOR RESIDENT INDIVIDUALS The schedular system implemented by the 2016 Tax Reform would be simplified by establishing only 2 schedules: (i) a general schedule, which would include labour income, pensions, capital income and non-labour income, and (ii) a schedule for dividends. The Tax Reform Bill establishes a fix amount of costs and deductions of 3 5%, limited to a 240 UVT per month (approx. COP 7,957,440 or USD 2,500). Currently, separate schedules for every type of income (labour income, pensions, capital income and non labour income) are in place. Each schedule has different rates, establishes different limits to costs and expenses and allows different deductions/exempt items of income. The current system does not provide fix costs and deductions. The proposed simplified general schedule would unify the rates, establishing a new rate bracket of 37% applicable to individuals with annual income higher than 13,100 UVT (approx. COP 434,343,600 or USD 137,000). Currently,

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labour and pension income highest rate is 33% and non-labour and capital income highest rate is 35%. The Tax Reform Bill would also eliminate the Income Tax exemption applicable to pensions. Currently, all pensions that do not exceed 1,000 UVT per month (approx. COP 33,156,000 or USD 10,400) are exempted. As previously explained in §4.2 the Tax Reform Bill is proposing the elimination of the assessment of the liability of individuals using the Alternate Minimum Taxable Income as taxable base, through a phase-out rate scale that would result in the repeal of this assessment mechanism as of 2021. The Capital Gains Tax (10%) and the Income Tax Rate for non-resident individuals (35%) remain unchanged.

_______ Please bear in mind that this is a selective summary, for informational purposes only, that focuses on certain topics of interest. Therefore, it is not intended to be a detailed and comprehensive dissertation of the topics discussed. It is advisable that our readers do not exclusively rely on this document and thoroughly review their queries, seeking qualified advice from professional tax attorneys duly admitted to the practice of law in Colombia. For more information on other changes in other pieces of legislation both at a national and local level, which are not featured in this issue of Colombian_Tax_Flash®, you can visit us on twitter @colombiatax. The use, translation, reproduction or retransmission by any means in whole or in part of this document is prohibited without the prior written consent of one of the partners of LEWIN & WILLS.

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NOTICE: ©2018 LEWIN & WILLS. All rights reserved. Colombian_Tax_Flash® is a periodical publication that discusses certain recent tax developments in Colombia. Please be advised that this summary is not intended to be a detailed and comprehensive description of the topics discussed herein. This publication is prepared by LEWIN & WILLS (Colombia) for informational purposes only and does not constitute legal advice. The statements contained herein reflect the author’s interpretation of current tax rules and may not be shared or accepted by the Colombian Tax Service or by the Colombian Courts or by other persons or authorities. The information contained herein is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Readers should not act upon it without seeking qualified advice from professional tax attorneys admitted to practice law in Colombia. This publication was not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any taxes or tax penalties that may be imposed on such person in Colombia or any other jurisdiction. Prior results do not guarantee a similar outcome. Colombian_Tax_Flash® is copyrighted material, the use,

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14Years November 16 , 2018, yr. 14 – Nolewinywills.com/.../11/Colombian-Tax-Flash-2018-Tax... · 1.2. New Colombian Holding Company (“CHC”) Regime The Tax Reform Bill proposes