The think tank estimated in November that the Financing Bill could cut foreign direct investment by USD 4.5B annually.
ANIF's diagnosis
On 26 November 2025, the National Association of Financial Institutions (ANIF) published its analysis of the aggregate impact of the Financing Bill. Conclusion: the rate increase combined with regulatory uncertainty would affect strategic sectors and FDI flow.
Most exposed sectors
- Hydrocarbons and mining: post-reform effective rate could exceed 70%, vs current 55%.
- Renewables: loss of transitional incentives affects solar and wind.
- Banking and financial services: additional surtax on income tax.
- Real estate: increased wealth tax compresses net yields.
The capital metric
ANIF quantifies exit risk at COP 18-22 trillion of private capital migrating to favourable jurisdictions (Panama, USA, UAE, Uruguay) between 2026 and 2028 if the reform passes in its current version.
T&C reading
Structured exit is NOT trivial. Requires modelling:
- Colombian exit tax: change of tax residence may trigger realisation of gains.
- CRS: automatic reporting of foreign accounts is already operative; there is no real opacity.
- Available treaties: Spain, UAE, UK, Switzerland offer differentiated frameworks.
- Substance: favourable jurisdictions require real, not nominal, presence.
Critical timing
Families evaluating restructuring must act before the 2025 fiscal close: any transaction executed in 2026 will be subject to the new rate framework, even if planning started earlier.