Colombia Issues Ruling on the Tax Obligations of Non-Resident when Selling Colombian Local Assets to another Non-Resident

Colombia's National Tax Authority (DIAN) has issued Ruling 53329 of 2014, which clarifies the tax obligations of a non-resident investor when selling local assets in Colombia to another non-resident. Key aspects of the ruling are summarized as follows:

• A sales transaction between non-resident parties involving local assets is not subject to Colombian withholding tax because non-residents are not considered withholding agents
• When a non-resident sells a local asset, a Colombian tax return mus…