The Colombian tax authority (DIAN) recently issued Executive Order No. 4 of 2020 concerning the application of the general anti-abuse rule (GAAR), which was amended with effect from 1 January 2017 by Law No. 1819 of 2016.

One of the key aspects of the order is definitions for the terms tax avoidance, which is subject to the GAAR, and tax evasion, which is not. Avoidance is an act where a taxp…