Colombia has published Decree 1103 of 10 August 2020, which provides regulations for the rules on the taxation of indirect transfers as reintroduced by Law 2010 of 2019. The rules were first introduced by Law 1943 of 2018 from 2019 but needed to be reintroduced by Law 2010 because Law 1943 was declared unconstitutional.

The Indirect Transfer Rules

As provided by article 62 of Law 2010, art…