Features

At the beginning of 2013, and after having had a very hard time trying to convince businesses to support the 2012 tax reform, the government promised that it would file a comprehensive tax reform to better articulate the tax system and in this way avoid the need of making reforms every other year to deal with budget constraints, writes Jaime Vargas, tax managing partner and international tax services leader at EY Colombia.

The past three years have seen significant changes to the Colombian tax framework, generally constituting a convergence with international tax concepts. Ximena Zuluaga and Luis Orlando Sánchez, of EY, explore the changes introduced by the 2012 tax reform and associated regulations released at the end of 2013 and assess the scope for further reform measures.

John Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.

Increased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan.

Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.