By Jean-Pierre Lenaerts and Publio Perilla Lozano
Although it is recognized that the absence of double-taxation treaties is clearly, by inference, an obstacle to international business, and that the presence or absence of a tax treaty is often a factor in international business and investment location decisions, Colombia is the only major Latin American country without a double-taxation treaty. One could take into account the Decision N° 40 of the Andean Pact but the benefit of this double-taxation agreement between the members of the Andean Pact is clearly limited and cannot be compared to the OECD Model Conventions.
However, among emerging market countries the treaty network is expanding rapidly, and as a result of this tendency, the Colombian authorities have now decided to start negotiating double-taxation conventions with some of Colombia’s major trade partners.
