Dividend taxation: Colombia may tax distributed profits to foreign beneficial owners subject to domestic law limits. Activities by an enterprise related to another enterprise shall be added together for computing time limits for permanent establishment when both enterprises perform identical or substantially similar activities for the same or connected project. The term 'fees for technical services' is clarified to include payments for services of technical or other personnel under the referenced domestic tax provision. Where domestic law is more beneficial to a resident of the other Contracting State, the more favourable domestic provision shall apply.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend taxation: Colombia may tax distributed profits to foreign beneficial owners subject to domestic law limits.
Activities by an enterprise related to another enterprise shall be added together for computing time limits for permanent establishment when both enterprises perform identical or substantially similar activities for the same or connected project. The term "fees for technical services" is clarified to include payments for services of technical or other personnel under the referenced domestic tax provision. Where domestic law is more beneficial to a resident of the other Contracting State, the more favourable domestic provision shall apply.
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