Tag: tax-case-law

The Colombian Supreme Administrative Court supports the inclusion of loss-making comparables if they maintain similar functional conditions, rejecting their automatic exclusion. This decision strengthens alignment with OECD guidelines and requires tax authorities to conduct more rigorous technical and economic analyses.

The assignment of image rights between artists or athletes and their own companies raises complex tax challenges. Current case law supports these operations if they are valued at arm’s length, but requires personal income tax to be applied to income from highly personal services performed directly by the individual.