CFCs are those entities that: Are controlled by one or more Colombian tax residents, according to the terms in the new legislation, (an entity is controlled if it is a related party due to the presumptions of subordination contemplated under transfer pricing rules). Do not have their tax residency in Colombia. CFCs include investment vehicles such as corporations, trusts, collective investment funds, other fiduciary businesses and private interest foundations, incorporated with operation or domiciled abroad, regardless if they are considered to be legal entities or not, or if they are disregarded for tax purposes or not. If the entity is established in a non-cooperative or low-tax jurisdiction, control is presumed regardless of the level of participation or involvement of the Colombian resident in the entity.