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RegulatoryColombia·Dec 20256 min

2025 fiscal close in Colombia and simulations for 2026

December decisions anchor the 2026 base. Five levers to evaluate before 31 December.

By T&C Consulting Group

The last close under the current regime

Regardless of the Financing Bill's fate, certain December 2025 decisions condition 2026 positions. T&C identifies five critical levers.

1. Distribution of accumulated dividends

Profits not declared by 31-Dec-2025 could fall under the new progressive scale (up to 41%) if the reform passes with retroactive effects to the start of the fiscal year. Declaring before year-end secures the current 15% rate.

2. Wealth normalisation

Law 2010 of 2019 opened normalisation windows. For undeclared assets, evaluate whether the new reform will include a similar window or whether voluntary declaration without reduced penalties is preferable.

3. 2025 inflation adjustments

Revaluation of real estate and fixed assets before year-end 2025: reduces future occasional gains on sale and wealth tax impact if the base increases.

4. 2025 deductible expenses

  • Donations to entities under special tax regime.
  • Science, technology and innovation investments (100% deduction).
  • Investments in zones most affected by conflict (ZOMAC).

5. Orderly exit structuring

For families decided to migrate fiscally:

  • Document fund source for future CRS.
  • Liquidate positions generating low occasional gains.
  • Constitute destination-jurisdiction vehicles before year-end 2025.
  • Evaluate exit tax on closely-held company shares.

Type simulation

Entrepreneur with personal holding of COP 50,000M:

  • Scenario A (2025 close with dividends declared): effective tax 22%.
  • Scenario B (retain profits to 2026 without reform): 22%.
  • Scenario C (retain to 2026 with reform passed): 38-41%.

The difference justifies urgent individualised analysis.

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