The Colombian tax authority (DIAN) recently released Ruling 805 of 23 September 2024, which provides guidance on the required certification of third-party debts for interest deduction purposes under the thin capitalization rules. As provided in paragraph 1 of Article 118-1 of the Tax Statute, where an unrelated resident or non-resident acts as a creditor, it must be certified that the credit or credits do not correspond to debt operations with related entities by means of a guarantee, back-to-back, or any other transaction in which related parties substantially act as creditors. As explained by Ruling 803, if such certification is not...