The Colombian tax authority (DIAN) has issued Concepto 3283 of 17 February 2020, which clarifies the impact of the 2016 income and capital tax treaty with the UK in triggering the MFN clauses of certain other Colombian tax treaties. The 2016 Colombia-UK tax treaty entered into force on 13 December 2019 and applies from 1 January 2020 for withholding tax purposes.

The main issue clarified is wi…