The Colombian tax authority (DIAN) recently published Ruling 579 of 13 May 2022 concerning the application of the concept of ultimate beneficial owner (UBO) under the new rules regarding the reporting of UBO information and the concept of beneficial owner under tax treaties. The ruling is in response to questions regarding the application of the 2005 Colombia-Spain tax treaty for dividends paid by a Colombian company that is wholly owned by a Spanish company that is wholly owned by an individual resident in Colombia. The ruling confirms that while the individual resident in Colombia is considered the UBO for the...