Colombia has ten tax agreements in force, as reported in its response to the Peer Review questionnaire, including the Decision 578 of the Andean Community Commission for the members of the Andean Community (the Andean Community Agreement).1

Colombia signed the MLI in 2017, listing nine tax agreements.2

Colombia is implementing the minimum standard through the inclusion of the preamble statement and the PPT combined with the LOB.3

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

Colombia indicated in its response to the Peer Review questionnaire that the Andean Community Agreement has not been listed under the MLI as it is a decision of the Andean Community Commission.

Colombia further indicated that bilateral negotiations would be used with respect to its agreement with Switzerland.

No jurisdiction has raised any concerns about their agreements with Colombia.

Colombia indicated that it encountered difficulties in the renegotiation of the Andean Community Agreement.4


← 1. The Decision of the Commission of the Andean Community 578 on the regime for the avoidance of double taxation and the prevention of fiscal evasion, adopted on 4 May 2004. The current members of the Andean Community are Bolivia*, Colombia, Ecuador* and Peru. In total, Colombia identified 12 "agreements" in its List of Tax agreements: nine bilateral agreements and the Andean Community Agreement.

← 2. In total, Colombia listed 10 agreements under the MLI, one of which (the agreement with France) is not yet in force.

← 3. For its agreements listed under the MLI, Colombia is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Colombia also opted for the simplified LOB under Article 7(6) of the MLI.

← 4. Bolivia* and Ecuador* are not members of the BEPS Inclusive Framework.

← 5. Colombia and Switzerland are finalising an Amending Protocol expected for signature during the summer of 2019. The Protocol adopts the preamble statement and the PPT.

Metadata, Legal and Rights

This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Extracts from publications may be subject to additional disclaimers, which are set out in the complete version of the publication, available at the link provided.

© OECD 2020

The use of this work, whether digital or print, is governed by the Terms and Conditions to be found at