DT5052 - Colombia: Double Taxation Relief Manual: Guidance by country: Treaty summary
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Colombia is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% (Note 1) | 10 |
| Dividends on direct investments | 5% | 10 |
| Conditions for lower rate on dividends on direct investments | A company which controls, directly or indirectly, at least 20% of the capital of the company paying the dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 10% (Note 2) | 11 |
| Royalties | 10% | 12 |
| Pensions | Taxable only in the UK | 17 |
| Arbitration | No | N/A |
Note 1: Dividends beneficially owned by a UK resident pension scheme are exempt from taxation in Colombia.
Note 2: Interest is taxable only in the UK where the beneficial owner of the interest is:
- the UK government, a territorial authority of the UK or the Bank of England, or
- a UK resident pension scheme
Interest is also taxable in the UK where the interest is paid:
- in respect of a loan guaranteed, insured or subsidised by the UK or Colombian government, or a person working on behalf of the UK or Colombian government
- on the sale on credit of industrial, commercial or scientific equipment, or on the sale on credit of goods or merchandise by an enterprise to another enterprise
- in respect of any loan or credit or whatever kind granted by a bank if the loan or credit concerned is granted for a period of not less than three years
- by a financial institution of Colombia to a financial institution of the UK