
2025 fiscal close in Colombia and simulations for 2026
December decisions anchor the 2026 base. Five levers to evaluate before 31 December.
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.