On 29 May 2020, the Colombian Government issued Decree 761, which contains the regulations to implement the thin capitalization rules established in Law 2010 of 2019 (i.e., the tax reform).

Background

Law 2010 of 2019 re-enacted the modifications to the thin capitalization rules that were previously introduced by Law 1943 of 2018, which was declared unconstitutional due to procedural …