The Colombian Tax Authority (DIAN) recently issued a ruling clarifying the application of the dividend withholding tax introduced by Law No. 1819 of 2016 (5% rate) and increased by Law No. 1943 of 2018 (7.5% rate). The ruling confirms that the withholding tax does not apply to dividends paid out of profits generated before 2017, regardless of when the dividends are declared and ordered to be pa…