Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

April 15, 2019

Colombia and Switzerland sign mutual agreement for Colombian tax residents to request refund of Swiss withholding tax on dividends and interest

On 1 March 2019, Colombia and Switzerland signed an agreement under Article 25 (Mutual Agreement Procedure) of their tax treaty, which provides the procedure for Colombian tax residents to request a refund or a partial exemption at source of Swiss withholding tax on dividends and interest.

Under the procedure, Colombian tax residents must:

  1. Complete Swiss Form 60 for a refund or Form 823B for a partial exemption at source for a substantial participation held in a Colombian company
  2. Submit the Swiss form to the Colombian Tax Authority, which will: (i) issue a tax residence certificate for the Colombian tax resident according to the Colombian domestic rules (including the year in which the person is a tax resident in Colombia); and then (ii) staple the Colombian tax residence certificate to the relevant Swiss form
  3. Submit the relevant Swiss form, with the Colombian tax residence certificate (not a copy), to the Swiss Federal Tax Administration in Bern

This procedure went into effect on 1 March 2019, and applies to all pending and future claims. If a past claim for benefits under the tax treaty was denied because a tax residence certification was not provided directly on the Swiss form, the Colombian tax resident will have to file a new request using the correct Swiss form and following the new procedure. In this case, the claim will be treated as if it was duly filed on the date of the first submission of the Swiss form for purposes of the Swiss statute of limitations.

For additional information with respect to this Alert, please contact the following:

Ernst & Young S.A.S., Bogotá
  • Luis Orlando Sánchez |
  • Andrés Millán |
  • Zulay Andrea Arévalo |
Ernst & Young, LLP, Latin American Business Center, New York
  • Juan Torres Richoux |
  • Ana Mingramm |
  • Enrique Perez Grovas |
  • Pablo Wejcman |
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
  • Jose Padilla |
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific
  • Raul Moreno, Tokyo |
  • Luis Coronado, Singapore |



The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


Copyright © 2024, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more