If the LLC qualifies as a Controlled Foreign Company (ECE, Arts. 882 to 893 Tax Statute) by virtue of Colombian resident control, passive income earned (such as bank interest, dividends, royalties, or financial returns) is attributed and taxed directly on the Colombian members' income tax return in the taxable year accrued, with no deferral until distribution. No automatic exclusion or guaranteed deferral should be assumed for active income: Article 885 of the Tax Statute establishes conclusive statutory presumptions (if passive income represents 80% or more of total income, all income, costs, and deductions yield passive income; conversely, if active income from real economic activities represents 80% or more, all income yields active income), requiring case-by-case financial and economic substance analysis, while Articles 882 to 893 govern the overall ECE regime and subsequent distributions of taxed earnings. Furthermore, if day-to-day strategic and operational decisions are executed from Colombia, DIAN may recharacterize the entity as having its Place of Effective Management in Colombia (Art. 12-1), subjecting it to worldwide Colombian corporate taxation.