Emerging Markets Rates and Currencies Handbook

Tax Summary – Colombia Colombia W/H Tax • 20% WHT if tenor < 360 days • 15% WHT if tenor > 360 days • Export financing exempt • Import financing: • 0% if <180 days; • 20% if between 180 and 360 days; • 15% if > 360 days • No WHT • Onshore: 2.5% WHT • Offshore: No WHT • 10%WHT on dividends Deductibility of interests and Derivative Settlements • Interest is deductible, unless D/E > 2x • Transfer Pricing rules apply (i.e. arms length rule) • Interest is deductible. • Thin cap does not apply, including loans with related party guarantee • Banking certification required • Fully deductible • Banking certification required • Onshore: Fully deductible • Offshore: Limited to 15% of net income before tax • Transaction needs to be directly related to “income producing activity” • N/A Deductibility of (FX) Losses • Fully deductible if loan is directly related to ”income producing activity • See above • N/A Other Taxes/Duties • 0.4% debit tax, unless the funds payable to a bank via USD offshore account (cuenta de compensación) • 0.4% debit tax • 0.4% tax if funds transferred from brokerage account to 3rd party Comments • N/A • N/A • N/A • OTC derivatives may only be closed with banks • N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing