Colombia's 2026 Economic Rescue Bill: key aspects of Bill 477 of 2026 (House)

On 29 October 2026 the national Government filed Bill 477 of 2026 with the House of Representatives, known as the Economic Rescue Bill (Ley de Rescate Económico). Its 106 articles combine public spending measures with changes to corporate and individual income tax, social security contributions, VAT, excise taxes and wealth tax, as well as a new Single Regime for Business Stability (Régimen Único para Generar Estabilidad Empresarial, RUGE) for large investments, a fiscal rule, control tools for the DIAN and a relief package to settle tax obligations.

This is a bill under debate. Until it is approved and enacted, current law applies, and its content may change during congressional debate. Several measures have specific application dates in 2027 and 2028, so it is useful to know them now in order to prepare scenarios.

The underlying reading

The bill lowers the nominal corporate income tax rate, but at the same time restricts the payroll contribution exemption companies enjoy today and broadens the VAT base. The net effect depends on each company's salary structure, the products it sells and its use of tax benefits. Not every company would pay less.

Three measures are best understood against current law: the contribution exemption is a restriction of today's benefit; the financial surcharge is an extension that raises the burden in 2028 to 2030; and the wealth tax is, in principle, a relief compared with the current regime. In addition, one measure is favourable for many domestic companies: the 15% minimum tax rate would be limited to large multinational groups.

Status at 4 November 2026: the bill is in committee. On 3 November the Government sent an urgency message (art. 163 of the Constitution), which allows joint sessions of the Third and Fourth Committees of the Senate and House. No committee reports had been published. Urgency shortens companies' planning time, and the text may change during debate.

Key aspects

• Public spending: powers to abolish or merge agencies, a 20% nominal cut in personnel spending in 2028, caps on growth in public procurement and transfer of special fund surpluses to the Treasury.
• Corporate income tax: the general rate would move from 35% to 33% in 2027 and 31% from 2028. For the financial sector, the surcharge would be extended: 38% in 2027 and 36% from 2028 to 2030, compared with the 40% and 35% current law provides.
• Minimum tax rate: the 15% minimum would no longer apply to all companies and would be limited to multinational groups with consolidated revenue of at least EUR 750 million.
• Payroll: a restriction of the current exemption. Today income-tax-filing companies do not pay SENA, ICBF or health contributions for employees earning under 10 minimum wages; from 2027 the full exemption would only cover employees up to 2 minimum wages, would be partial between 2 and 3, and would disappear above 3.
• Individuals: exempt labour income of 25% capped at 630 UVT per year and a top marginal rate of 39% from 8,670 UVT.
• Wealth tax: in principle, a relief. The threshold would rise from 72,000 to 95,500 UVT and the top rate would be 1%, from 2027 to 2030.
• VAT: from enactment, services that are excluded today, such as software and cloud computing, would be taxed; from 2028 the lists of excluded and exempt goods and services are replaced, and EfectIVA is created, an individual refund based on eligibility tiers.
• Excise: changes to taxes on liquor, tobacco, beer and sweetened beverages.
• RUGE (Single Regime for Business Stability): a 20% income tax rate for large projects starting execution in 2027 or 2028 and 26% from 2029, an 8% dividend rate for non-residents and 16-year stability.
• Normalisation and relief: normalisation at 15% (5% for crypto-assets) in 2027, and reduced DIAN penalties and interest with a deadline of 30 June 2027.

Who it would apply to and what to review

How to read the detail

Below, the changes are described title by title, with the figures, exceptions and conditions of the articles. Where the bill's text is ambiguous or inconsistent, this is expressly flagged rather than resolved by interpretation. VAT lists are presented as summaries; each transaction must be checked against the literal description, tariff heading and conditions in the text. Review date: 4 November 2026.

The bill at a glance

Key figures

Corporate income tax: what really changes

The general rate under article 240 of the Tax Code would fall from 35% to 33% in 2027 and to 31% from 2028. It applies to domestic companies, permanent establishments and foreign legal entities that file returns. It does not replace regimes with their own rate, such as free trade zone users (art. 240-1), the special tax regime, SIMPLE and the differential rates in article 240 (hotels, publishers, extractive surcharges), unless the text says so; article 57 does not expressly clarify whether it amends those paragraphs.

What companies actually pay depends on the effective rate: adjustments, exempt income, credits (including 50% of ICA, if retained), the minimum tax and surcharges. Two companies with the same nominal rate can bear very different effective burdens.

Illustrative example. Taxable income of COP 10,000 million, all other assumptions constant (no surcharges, minimum tax or credits). Figures in COP million.

Four points less in rate means paying 11.4% less tax. Profit available to reinvest or distribute grows by 6.2%, before dividend tax at shareholder level.

Financial sector, year by year. For financial institutions, insurers and the other listed entities with taxable income of 120,000 UVT or more, current law provides 40% until 2027 and 35% from 2028. The bill sets 38% in 2027 and 36% from 2028 to 2030: a 2-point relief in 2027 and a 1-point increase in the following three years, because it extends the surcharge.

Minimum tax rate. Today the 15% minimum rate (para. 6, art. 240 Tax Code) applies generally to income taxpayers, with some exceptions set out in the same provision. The bill would limit it to entities in multinational groups with consolidated revenue of at least EUR 750 million. For many domestic companies this would remove a calculation that can currently raise their tax, and it is one of the bill's most favourable measures for this audience.

Context. Three perspectives are worth separating. The Government justifies the rate cut on competitiveness grounds: at 35%, Colombia currently has one of the highest nominal corporate rates among OECD countries. According to the explanatory memorandum, as cited by Fedesarrollo, the bill also seeks to «narrow the generous employer contribution exemption». Business associations such as the National Coffee Growers Federation and Aconauto have publicly questioned the VAT increase from 5% to 19% on coffee and electric vehicles. T&C's reading is that the nominal cut is real, but its effect on each company must be measured together with payroll, VAT and the effective rate.

Title I. A smaller State and new funding for social security

Purpose and public spending (articles 1 to 19)

Article 1 sets out the purpose of the law. The rest of this chapter is addressed to the Government and public entities:

• 2027 spending cuts and deferrals (art. 2): the Government could defer or reduce budget items mandated by laws lacking a favourable opinion from the Higher Council for Fiscal Policy.
• Special fund surpluses (art. 3): balances available at 31 December, neither committed nor allocated to payable obligations or duly enforceable commitments, would move to the Treasury to reduce financing needs. Resource-management mechanisms for healthcare, pensions and benefits and coverage under the comprehensive social-security system are excluded.
• Review of spending mandates (arts. 4 and 5): an efficiency programme and a technical study would propose repealing earmarked revenues and funds that have served their purpose.
• Transfers based on actual collection (art. 6): revenue-linked transfers would be settled on actual collections, except the General Participation System.
• Six-month extraordinary powers (art. 7): to abolish, merge or split ministries, superintendencies and national entities.
• Official advertising and austerity (arts. 8 and 9): advertising limited to public-interest information and an annual austerity plan.
• Growth caps (art. 10): from 2027 to 2030, appropriations for goods and services of national-budget bodies, whether operating or investment expenditure, would grow at most by the previous year-end CPI, with additional execution-stage reductions. Article 10 contains no exception for commercial or production spending.
• Sale of State assets (arts. 11 to 15): entities must report unneeded assets to CISA, and the sale of shareholdings is streamlined with an abbreviated procedure and 30-day offers.
• Staff and contractors (arts. 16 and 17): in 2028 personnel spending by national-budget entities, excluding the public force, would fall nominally by 20%. In 2029 and 2030 its maximum growth would be 0.5 percentage points above the average inflation target projected for the budget. Professional and management-support personnel contracting costs would fall 50% in 2027 versus 2026, not the number of contracts. From 2028 this spending would have a growth ceiling equal to the previous year's CPI.
• Tourism (arts. 18 and 19): FONTUR's management is adjusted and the "Tourism Tax" name is unified.

Public spending and asset qualifications

• Art. 2: covers only current and capital transfers under CONFIS review. In addition to deferral or reduction in 2027, it would prohibit including transfers lacking a favourable opinion or receiving an unfavourable opinion in the proposed 2028 to 2030 budgets, maintaining the reductions and covering other appropriations identified under that criterion. Constitutional expenditure remains protected and spending laws are not repealed. A favourable opinion allows reinstatement subject to resources.
• Arts. 4 and 5: programme and technical study, not automatic repeal. Optional study in the first half of 2027; bill before end-2028 and new initiatives every four years from 2031. Sector reports, individual evaluation and protection of rights and existing earmarks.
• Art. 7: powers exclude taxes, codes, organic/statutory legislation and public-force staffing. Employment and specified personal protections, studies and oversight; no evasive contracting to replace abolished posts.
• Art. 8: national executive advertising requires prior written DAPRE clearance; print only with justified lack of digital access. Government/personal promotion and evasion prohibited; conditional exceptions for competing State enterprises and mixed companies.
• Art. 9: annual austerity covers travel, vehicles, property, overtime, advertising and other costs, plans/reports and branch/body autonomy.
• Art. 11: unnecessary-asset reporting within 45 days and annually in the first quarter; free transfer to CISA within 30 days under conditions. Net proceeds to Treasury the next month, at least 50% for debt for four years. Exceptions cover constitutionally protected/public-use property, vacant public lands, defence, cultural heritage and SAE-managed assets. Specific valuation, previously transferred but unsold-at-1-June-2027, reversion and liquidation rules; not automatic sale of all assets.
• Art. 12: share-sale programme design/valuation; valuation up to twelve months and updating without lowering approved minimum prices. A historical 1998 reference is not a future date.
• Art. 13: simultaneous offer of registered shares with absolute priority for special recipients and remainder to the public; thirty calendar days.
• Art. 14: private-law procurement of studies, valuations and brokerage, without removing other sale requirements.
• Art. 15: direct or specialist promotion and thirty-day offers for special recipients.

Why it matters: suppliers and contractors to the State should expect less contracting and tighter budgets from 2027. The sale of public assets may open investment opportunities.

Social security (articles 20 to 26)

• Restriction of the payroll contribution exemption (art. 20, amendment of art. 114-1 Tax Code): today income-tax-filing companies do not pay SENA (2%), ICBF (3%) or health (8.5%) for employees earning under 10 minimum wages. From 1 January 2027, one year before the 31% income tax rate, the full exemption would only cover employees earning up to 2 minimum wages. Above 2 and up to 3 minimum wages they would pay 1% SENA, 1% ICBF and 4% health. Above 3 minimum wages they would pay the full 13.5 points. For many companies this means higher payroll costs from 1 January 2027. Individual employers would also receive full or partial relief under the conditions previously stated. In addition, the text exempts those employing two to five workers without restating a salary ceiling there; the interaction of this additional provision with the general rules requires clarification. Consortia, temporary unions and autonomous estates must meet the membership conditions. Entities subject to qualification under Tax Code article 19 would remain liable; those under article 19-4 retain the benefit. Public higher-education institutions would not contribute to SENA.
• Employee health contributions (art. 21): from 1 January 2027 the general employer rate remains 8.5%, subject to the full exemption or reduced 4% rate described above. On contribution-base income, subject to a one-minimum-wage floor, employees would contribute 4% up to 2 minimum wages; 5.5% above 2 to 4; 6% above 4 to 5; 6.5% above 5 to 10; 7% above 10 to 15; 7.5% above 15 to 20; and 8% above 20 to 25. For independent workers: 12.5% up to 2 minimum wages; 13% above 2 to 4; 13.5% above 4 to 5; 14% above 5 to 10; 14.5% above 10 to 15; 15% above 15 to 20; and 15.5% above 20 to 25. In special and exception regimes, the employer contribution would remain 1.5%; from 2027 the employee contribution earmarked for the subsidised regime would increase by 1.5% for contribution bases above 2 and up to 3 minimum wages, and by 2.5% above 3 minimum wages. These are increases stated in the bill, not verified total rates.
• Family compensation funds (arts. 22 to 24): one of their four percentage points would go to ADRES for health insurance; they could use FOSFEC balances to settle health liabilities, and the fund's 2026 surpluses would go to healthcare.
• Pensions (arts. 25 and 26): reserves for life annuities would be funded with Government bonds, with rules to transfer to the Contributory Pillar Savings Fund the resources of those who switched regimes.

Funds and pensions, qualifications: article 22 redirects one of four contribution points to ADRES. Article 23 permits specified FOSFEC balances for audited, reconciled and recognised health liabilities for five years while preserving unemployment benefits. Article 24 directs available end-2026 surpluses after legal obligations; its recipient name is incomplete and no transfer deadline is invented. Article 25 addresses the specific annuity coverage-mechanism reserve, not all annuity reserves. Article 26 retains AFP administration until pension rights consolidate and governs FAPC transfers, certified payments and a Treasury transitional portfolio; the remainder transfers within six months of FAPC operation, not immediately for everyone.

Why it matters: for companies with employees earning more than 2 minimum wages, the higher contribution cost may fully or partly offset the saving from the lower income tax rate. The result depends on each company's salary structure. As a reference, for every COP 100 million of annual salaries of employees earning above 3 and under 10 minimum wages, the employer would pay an additional COP 13.5 million in contributions; offsetting this with the 4-point rate cut from 2028 would require around COP 337.5 million of taxable income, before considering that contributions are deductible. High-income employees would pay more for healthcare.

Liquor, tobacco and beer (articles 27 to 37)

• VAT on liquor (art. 27): spirits, wines and aperitifs would be subject to VAT at the general rate, with revenue assigned to the departments for healthcare.
• Liquor excise (art. 28): COP 750 per alcohol degree per 750 cc plus a 35% ad valorem component.
• Tobacco (arts. 29 to 32): cigarettes, tobacco, cigars, cigarillos and heated tobacco would have a specific component of COP 7,823 per twenty-unit pack in 2027 and COP 11,200 from 2028, proportionately to content, plus 10% ad valorem. Cut tobacco, snuff and chimu: COP 891 per gram plus 10% ad valorem on that specific component. Derivatives, substitutes or imitators: COP 1,000 per millilitre in 2027 and COP 2,000 from 2028, plus 30% ad valorem on DANE-certified retail prices. From 2029 rates would be updated by CPI plus four points.
• Beer and related beverages (arts. 33 to 36): the levy is renamed a production tax without changing its nature or its national-consumption taxable event. For beer, sifones, refajos and covered mixtures, the proposed rates are COP 330 per alcohol degree per 330 cc or equivalent, plus 10% ad valorem; alcohol-free beer pays only the ad valorem component.
• Use of additional revenue (art. 37): new revenue would fund health insurance.

Excise qualifications: article 29 defines tobacco and derivatives, including electronic systems with or without nicotine; excludes inputs for taxed production and artisanal chicote. Article 30 covers producers/importers, distributor joint liability and carrier/retailer liability if origin is not justified. Article 31 uses DANE retail prices excluding VAT/excise for general ad valorem; article 32 gives a different specific rule for cut tobacco, snuff and chimu. Article 33 renames beer taxation without changing its nature; article 34 retains national consumption and excludes exports; article 35 distinguishes alcohol content and DANE prices without VAT/excise. Articles 28/36 index specific components from 2028 by CPI plus four points and contain Archipelago conditions: imported products excluded unless subsequently introduced to the rest of the country; only domestic liquor has an express COP 61-per-degree-per-750-cc rate. Article 37 calculates additional revenue against the corresponding 2026 month updated, not confusing this historic revenue base with rates; ADRES transfers within the first fifteen working days each month.

Title II. EfectIVA and revenue measures

EfectIVA (articles 38 to 40)

• Beneficiaries and amount (art. 38): from 1 January 2028, individually identified residents in poverty, extreme poverty or vulnerability could receive a refund per person, not per household. Refunds would be 100% for poverty and the lowest vulnerability bracket; 50%, 40% or 30% for other brackets defined by DNP and Finance. The monthly ceiling is up to 5.5 UVT, not a fixed payment, with prescribed annual adjustment and determination. The extreme-poverty minimum is not added to the calculation: the higher amount applies, within the ceiling.
• Administration and payment (art. 39): DIAN would determine VAT paid from invoicing and DPS would administer beneficiaries and payments. Ordinary periods would not exceed fifteen calendar days; beneficiaries without deposit products would receive monthly or bimonthly cash transfers under the operating manual. Financial enquiries to select payment channels do not cover balances or verify income. Credit purchases remain subject to traceability and regulation.
• Protection and transition (art. 40): it would be neither a subsidy nor an ordinary credit-balance refund; it would not constitute taxable income and would be protected from withholding, financial transactions tax, attachment and bank offsetting. Twelve-month expiry requires failure to collect attributable to the beneficiary. Rules cover duplication, adjustments, repayment and abuse with due process, an unpaid pilot, an advance by 20 December 2027 and transition without aggregate household reductions or double benefits. Universal fortnightly cash payments cannot be promised. In addition, subject to technical, operational and legal feasibility, DIAN, coordinating with DPS and the Finance Ministry, could implement the benefit directly at the point of sale by not charging the applicable proportion of VAT, without prior payment or a subsequent refund.

VAT (articles 41 to 46)

• Games of chance (art. 41): general-rate VAT except lotteries, with operator liability including overseas operators under the specified territorial link. The general base would be the wager or participation instrument; for exclusively online games it would be the user deposit divided by 1.19, including crypto-asset deposits. Located games would retain specific monthly UVT bases by modality.
• Excluded goods (art. 42): from 2028, a replacement of Tax Code article 424. It covers specified tuna and dried or smoked fish; natural milk components; potatoes, legumes, tubers, rice, artisanal panela, Bienestarina, bread and arepa; unsweetened unflavoured water; coal, coke, gases and electricity; medical radioactive materials, dressings, condoms; wood, expressly classified building materials, legal currency, disability mobility aids and parts, lenses, catheters, infusion equipment, orthopaedics and accessibility under heading 90.21, and pencils. General labels do not expand the specific tariff headings and descriptions. Additional items cover proven vaccine inputs; special enteral nutrition; female contraceptives; neighbouring-country food for local use in Vichada, Guainia and Vaupes; qualifying food-bank donations; museum objects; real estate; specified consumption and building goods for those departments; aviation fuel on listed routes; Amazonas border-treaty products; ACPM producer income; and ANH royalty crude. Express territorial rules exclude liquor subject to excise or monopoly and taxed beer and mixtures.
• Excluded services (art. 45): from 2028, replacement article 476 contains 23 items: (1) human healthcare; (2) State-fund administration and social security; (3) specified mandatory plans and health, pension and occupational-risk administrators; (4) brokering such untaxed plans; (5) recognised education, related services and public assessments; (6) regulated digital-content virtual education; (7) public land, river or maritime passenger transport, freight, gas and hydrocarbon transport; (8) air routes without organised land transport and listed tourist destinations; (9) energy; (10) water, sewerage and public sanitation; (11) domestic gas; (12) public-funded catering for listed institutions; (13) residential leases and craft/cultural spaces; (14) credit interest outside article 447 bases and leasing; (15) social-transfer intermediation; (16) funerals; (17) securitisation commissions paid from vehicle resources; (18) collective-fund management; (19) tourism and hotels in specified special customs zones; (20) foreign exchange and related derivatives; (21) card commissions; (22) reinsurance brokerage; (23) additional health plans. Manufacturing to order follows the resulting goods rate, except mining and hydrocarbons.
• Exempt goods (art. 46): from 2028, replacement article 477 allows offsets and refunds for specifically listed meats and offal; fresh/frozen fish and fillets with tuna exceptions; milk, cream, eggs and rice within literal limits; salchichon, butifarra and mortadella; infant formula and preparations; vitamins, antibiotics, therapeutic substances, blood, vaccines and medicines under the listed headings; exclusive-use arms and sanitary towels. Additional categories include domestic biodiesel for diesel blending; limited defence material and defence-sector services; bicycles, motorcycles, motor-tricycles and parts for Amazonas, Guainia, Guaviare, Vaupes and Vichada under exclusive-use and registration conditions; and consumption/building goods for Amazonas subject to purchaser, invoicing and transport conditions. Uniforms and expressly excepted defence textiles are not included. Liable producers keep accounts and seek refunds at the two prescribed annual opportunities. Exclusion and exemption differ. Rice appears in both lists: this overlap is not resolved as a tax certainty.
• Fuels (arts. 43 and 44): article 43 would change the liable parties from 1 January 2028. Article 44 would change taxable bases under the general commencement rule upon promulgation, except rules expressly deferred to 2028 for retailers. Specific exclusions cover producer income for ACPM and diesel-engine blends and their retail sale; transport is excluded from the expressly identified bases.
• Related repeals (art. 106): the 5% rates (arts. 468-1 and 468-3 Tax Code) disappear from 2028, as do several exclusions linked to vehicles and equipment once the law takes effect.

Fuel liability and dates: article 43 starts in 2028 and limits producer/importer and retailer liability to regular motor gasoline and oxygenated regular gasoline under express bases. Article 44 includes wholesaler/industrial marketer bases, 100/130 aviation gasoline, other non-fuel and unregulated derivatives, imports and credits; a stated base alone does not establish universal liability.

Why it matters: for technology, services and retail companies, the cost may begin in 2027 rather than 2028. From enactment, services excluded today, such as software, web hosting and cloud computing, would be taxed, and other exclusions and the 5% rate for electric and hybrid vehicles would disappear. From 2028 the 5% rate would be abolished and the lists of excluded and exempt items replaced. The effect on margins is not always negative. For each product it is worth measuring: (i) the effect on price and demand, (ii) whether moving from excluded to taxed allows input VAT that is a cost today to be credited, and (iii) the cash effect of credit balances and refunds.

Individuals (articles 47 to 51)

• Labour exempt income (art. 47): the 25% exemption would be capped at 630 UVT annually and calculated after deducting non-taxable income, deductions and other exemptions, not automatically on gross salary.
• New rate table (art. 48): 0% up to 720 UVT, then 9%, 19%, 28%, 33% and 39% above 8,670 UVT.
• Cap on benefits (art. 49): exempt income and deductions in the general schedule limited to 40% and 1,180 UVT a year.
• Payroll withholding (art. 50): a new monthly table consistent with the income tax table.
• Inflationary component (art. 51): the treatment of interest and financial costs would apply only to individuals and undivided estates not required to keep accounting books. Article 106 also repeals the non-taxable inflationary component of financial yields.

Why it matters: the proposal sets a zero-rate bracket and benefit caps and proposes marginal-rate and payroll-withholding tables. The effect must be calculated for each taxpayer's taxable base and benefits; a general reduction for middle incomes cannot be asserted.

Proposed income and withholding tables

Marginal rates, not percentages on all gross income. Constants are retained as printed in articles 48 and 50; small arithmetic discontinuities are not silently repaired.

Article 49 jointly caps benefits at 40% of the preceding item result and 1,180 UVT. Under article 50, non-employment work income follows the table without a costs election; with costs, article 392 applies. Payments are monthly allocated after contributions and divided by contract months. Exempt pensions do not bear this withholding. Written requests for higher rates apply from the next month.

Other taxes (articles 52 to 56)

• Lotteries, raffles and betting (art. 52): a 30% rate is proposed for these occasional gains, not for all categories of occasional gains.
• Carbon tax (arts. 53 to 55): carbon-neutral certification could only reduce up to 25% of the tax; proposed rates are 0.87 UVT per tonne of CO₂eq in 2027, 1.23 in 2028 and 1.59 from 2029, with a fuel-specific schedule. Twenty percent of revenue would fund PNIS; FONSUREC is created, but the text does not expressly allocate the remaining 80% to it. Used certification cannot be reused for that or another tax benefit.
• Ultra-processed sweetened beverages (art. 56): from 2028, COP 45 per 100 ml if they contain less than 9 g of added sugar or only sweeteners, and COP 76 if they contain 9 g or more. Concentrates, powders and syrups are included.

Beverage scope (art. 56): headings 19.01 with specified exceptions, 20.09, 21.01, 22.02 and subheadings 2106.90.21.00/2106.90.29.00 apply only within the added-sugar and/or sweetener definition. Without either, no tax. Qualifying donations are outside the taxable event and producer exports do not trigger it; exemptions cover infant formula, medicines, nutritional therapy, special medical foods and oral electrolyte solutions for illness. Producer/importer liable; natural-person producers below 10,000 UVT activity income have the text's temporally qualified exception. UVT adjustment from 2029. PDF visual formula, p. 266: tax = volume in ml / 100 × rate, without adding rates when both sugar and sweeteners occur. Preparations use instructed final volume. Liability arises on invoicing or delivery/withdrawal, imports on clearance. Buyer treatment: increased cost/deductible cost under article 115, not creditable VAT; separately invoiced.

Title III. Companies, local governments and wealth

• Income tax rate (art. 57): 33% in 2027 and 31% from 2028. For financial institutions and insurers with taxable income of 120,000 UVT or more, the surcharge would be extended to 2030: 38% in 2027 and 36% from 2028 to 2030, compared with 40% and 35% under current law. The minimum tax rate would be limited to multinational groups.

Art. 57 qualification: surcharges also list reinsurers, securities/agricultural brokers, goods/commodity exchanges and securities-market infrastructure providers. A 100% advance on the preceding-year base is paid in two instalments. The 15% minimum is not universal: it covers specified entities in multinational groups with prior consolidated income of at least EUR 750 million or the stated converted equivalent. Adjusted tax rate = adjusted tax / adjusted profit, with individual/consolidated calculations and listed exclusions, including non-positive adjusted profits and referenced Tax Code cases.

Territorial borrowing and budgets, article by article

• Art. 58: calculation includes income and expenditure of all territorial budget bodies, including public establishments and equivalents.
• Art. 59: redefines operating savings, income, operating expenditure and transfers. Salaries, fees, benefits and social security remain operating costs even when budgeted as investment. Surpluses, dividends and profits count only if received in each of the previous four years. Credit finances investment, except short-term, refinancing and workforce-reduction indemnities. The subtraction wording has a syntactic defect; an interpreted formula is not presented as a literal quote.
• Art. 60: restrictions if interest/operating savings exceeds 60% or debt/current revenue exceeds 140%. Exceptions fund only non-financial asset acquisition: departments and special-to-second-category districts/municipalities require AA+ for local credit or authorisation and sovereign-equivalent rating for external credit; third-to-sixth-category entities require Finance authorisation and performance plans.
• Art. 61: 15% appropriation in the authorisation year for future commitments; lower execution only where the contract schedule requires it.
• Art. 62: deductions of future commitments from debt-capacity income under the stated operating/recurrent-spending boundary. Listed categories include security, cleaning, school food/transport, public lighting, catering, specified rents, digitisation and archives; coordination requires caution, not a blanket exception for all recurrent costs.
• Art. 63: listed continuity services may affect the next government's first year, only through its first quarter and at most 20% of the authorisation-year investment or operating budget as applicable. Last-year authorisation does not require strategic-importance designation. Public lighting is not on this list.
• Art. 64: securitisation generally cannot outlast the mandate; the literal exception for departments, districts and special-category municipalities requires authorisation from the relevant departmental assembly or municipal/district council, proceeds devoted exclusively to investment projects implementing the objectives and strategies of the strategic component of the current territorial development plan and included in its annual operational investment plan, and a ceiling of 10% of future own-revenue collection flows in each fiscal year covered by the transaction. Exceptional operations do not enter debt indicators. The special-category wording is not editorially expanded to unclear beneficiaries.
• Art. 65: general-purpose FONPET surpluses fund development-plan investment where pension liabilities are 100% covered or health/education are adequately financed by sufficient future revenues and returns within the legal period; annual withdrawals follow a methodology safeguarding pensions.

• Wealth tax (arts. 66 to 68): would apply in tax years 2027 to 2030 where net worth at 1 January is at least 95,500 UVT. Tax is zero on a taxable base up to 95,500 UVT; above that to 145,500 UVT it is 0.5% of the excess over 95,500 UVT; above 145,500 UVT it is 250 UVT plus 1% of the excess over 145,500 UVT. Compared with current law (72,000 UVT threshold and marginal rates of 0.5% to 1.5%, with 1.5% scheduled until 2026), this is in principle a relief: net worth between 72,000 and 95,500 UVT would no longer be taxed and the top rate would be 1%. Which regime would apply after 2030 should be checked against the text.

Why it matters: with the rate cut, the timing of income and expense recognition between 2026 and 2028 deserves review. Business families should prepare the valuation of their assets at 1 January 2027.

Title IV. Attracting capital

RUGE (article 69, new articles 917 to 925 Tax Code)

For the investor, in three lines. Benefits: a reduced income tax rate, an 8% dividend rate for non-residents and 16-year stability. Costs: an annual premium of 0.1% of executed investment, a 2% guarantee and minimum purchases from domestic suppliers. Risk: this is a bill under urgent debate, and thresholds, rates and requirements may change in Congress.

The Single Regime for Business Stability seeks to attract large new investments:

Benefits during the stability period (art. 919):

• 20% income tax for projects beginning execution in 2027 or 2028, and 26% for those beginning from 2029, retaining the cohort rate during stability without surcharges. Ordinary commencement is certificate registration; for public-private partnerships (PPPs), the construction-start record.
• 8% final tax on dividends to non-residents, which can be passed through Colombian companies.
• Accelerated depreciation: up to 50% a year for machinery, equipment and networks, and 10% for buildings.
• The project vehicle would not be subject to wealth tax; investors would tax their holdings under the rules in effect at execution commencement.
• Temporary tariff treatment for capital goods not produced locally (art. 920).
• Ordinary stability for 16 years, subject to verifiable commitments and grounds for loss. For PPPs, from construction commencement and not beyond the contract term; VAT, territorial taxes, social security, royalties and labour, environmental, criminal and other expressly excluded rules are not stabilised (arts. 921 to 925).

Benefits could not be combined with free trade zones, ZOMAC, ZESE, exempt income under Tax Code article 235-2 or the Legislative Decree 1413 of 2026 cited in the bill. Projects within free-zone areas or declared special permanent free zones could not enter; their users could participate through a new vehicle and project outside the area.

RUGE conditions (art. 69): ordinary applications by 31 December 2029; PPPs by 31 December 2031, from award and before more than 10% of private investment is executed. Exclusive vehicle without operating revenue; land, working capital, shares, reorganisations, existing assets, portfolios and public debt do not count. Advances to capital-goods suppliers and project construction contractors count up to 30% of committed investment, backed by a binding contract and security for proper management and investment of the advance; any excess counts when goods are delivered or works executed; same-project investment within the preceding twelve months may count without retroactive benefit. CIIU sections G, K, L, O, T and U are excluded; not a regime for all real-estate or trading businesses.

Ordinary execution requires 40% in two years and 100% within sector deadlines; PPPs, at least 40% of committed private investment within three years after the construction commencement certificate; full execution within the contractual construction period, capped at ten years; automatic termination if that certificate is not signed within three years after registration of the adhesion certificate. Public contributions and preconstruction/construction tolls do not count. Benefits must be reflected in PPP contracts. Throughout execution and the first five operating years, at least 30% of the value of project purchases of goods and services must be sourced from national suppliers, excluding goods without national production and land from the calculation base. At least one third of that percentage must go to micro, small or medium-sized enterprises or suppliers domiciled in the project's department; the supplier development plan must be implemented. Minimum security: 2% of committed investment; annual premium of 0.1% of cumulative executed investment as at 31 December of the preceding year, throughout the stability period, not an income-tax advance. Investment, purchase and employment reports; employment is not a retention criterion.

New articles 922 to 925: reduction/loss according to execution, suppliers, fraud, convictions or unpaid premiums, with due process. Initial execution from 30% to under 40% may receive twelve extra months upon proven non-attributable cause; under 30%, termination/repayment. Final execution meeting threshold but not commitment: 50% benefit reduction; fraud: repayment, fine of 10% to 50% of benefits and five-year disqualification. Human committee issues reasoned decisions; AI only supports. Ordinary technical/decision stages of fifteen working days each, one information request and absolute three-month maximum; positive silence subject to requirements and non-response exception. Regulation within three months, without its absence blocking access.

RUGE: how the 20% rate would work for foreign investors

A preliminary clarification. RUGE is not a regime reserved for foreigners: the bill expressly states that it "does not distinguish between domestic and foreign investment". Some of its elements are particularly relevant for capital from abroad: the 8% dividend rate applies to non-resident shareholders, stability covers foreign-exchange rights to repatriate capital and remit profits, and the investment thresholds target projects usually financed with international capital.

Combined burden. For a foreign investor, the tax cost includes company-level tax and the tax paid when profits are distributed. Using the bill's rates, the calculation would be approximately as follows for every 100 of profit:

The difference would be about 18 points against the general regime and around 5.5 points between the two RUGE cohorts. This is an illustrative calculation: it excludes double tax treaties, tax credits in the investor's country, the minimum tax rate and the effect of accelerated depreciation, and article 245 of the Tax Code could be amended by other means.

Other benefits of the regime. In addition to the rate, the bill provides for: accelerated depreciation of up to 50% per year on machinery and equipment brings forward capital recovery; the vehicle does not pay wealth tax; and 16-year stability protects the rate against surcharges or new national taxes on income. The bill clarifies that, for the minimum tax rate under paragraph 6 of article 240 of the Tax Code, the timing difference created by accelerated depreciation is disregarded.

Execution start date. The 20% rate depends on the project starting execution in 2027 or 2028, and the bill defines that start as the registration of the adhesion certificate in the RUGE Public Registry (for PPPs, the signing of the construction start record). In practice, anyone seeking the 20% cohort must have the project structured, the vehicle incorporated and the application ready with sufficient margin before the end of 2028, considering the review times provided for.

Access requirements:

1. That it is new investment. Share purchases, acquisitions of existing assets or businesses, reorganisations, transfers between related parties, portfolio investment and public debt do not count; nor do land or working capital for the threshold. Acquisitions of Colombian companies, on their own, do not qualify.
2. That it reaches the sector threshold (from 2,580,000 to 8,140,000 UVT depending on the sector) and that the activity is not in the excluded ISIC sections, including trade, financial and real estate activities.
3. That the vehicle is exclusive to the project, a Colombian company or a branch of a foreign company, without mixing other businesses.
4. That it can meet the obligations: 40% of the investment executed within two years, 30% of purchases from domestic suppliers (one third of that percentage from SMEs or suppliers in the department), a minimum 2% guarantee and an annual premium of 0.1% on cumulative executed investment throughout the stability period. This premium is an additional cost to include in the model.
5. That it does not rely on other incentives. RUGE cannot be combined with free trade zones, ZOMAC, ZESE or exempt income under article 235-2 of the Tax Code; it is worth comparing which regime works best for each project.

Conditions to remain in the regime. Missing milestones may reduce or forfeit benefits, with repayment of the taxes saved, and fraud carries fines and a ban. Moreover, this is a bill: the rate, thresholds and the 2027 and 2028 cohort may change in Congress, and regulations will define operational aspects. Project analyses should therefore be built on scenarios (with and without RUGE, and with different start dates) until the approved text is known.

Tax normalisation (articles 70 and 71)

• General (art. 70): 15% on omitted or undervalued assets and non-existent liabilities at 1 January 2027. Base: tax cost or supported commercial self-valuation not below tax cost; for liabilities, tax value or the last return. Includes look-through rules for overseas trusts, foundations and other vehicles and adjustment of assets other than inventory. Separate return, assessment and payment by 30 June 2027, without late filing or subsequent amendment. Neither deductible nor creditable; specified effects address net-worth comparison, penalties and criminal action for the regularised omission, without legalising illicit assets or requiring repatriation under this article.
• Crypto-assets (art. 71): a preferential one-off 5% regime on peso market value of omitted assets directly or indirectly held at 1 January 2027, without duplicating underlying assets and tokens. Without verifiable quotes a reasonable documented method is required. Return, full payment, information and amendments by 30 June 2027. Assets, custodians, public addresses and decentralised positions must be identified, never private keys or recovery phrases. Tax cost starts in 2027. It does not regularise earnings or transactions beyond the patrimonial omission, illicit origins or confer general criminal immunity.

Title V. Fiscal rule and institutions (articles 72 to 81)

• New fiscal rule (art. 72): a debt limit of 71% of GDP and an anchor of 55%, with primary balance targets set at the start of each administration.
• Control account and automatic correction (arts. 73 to 75): a control-account balance equal to or below minus 0.5% of GDP triggers adjustment by 31 March of the following year through a bill and/or administrative acts, to restore a non-negative balance within two fiscal years. The account starts with the 2027 deviation and does not accumulate deviations during the escape clause. Without correction, ceilings apply according to debt below or from 63%, subject to the stated exceptions.
• Reporting and compliance (arts. 76 to 78): greater accountability to Congress and consistency between the Medium-Term Fiscal Framework and the budget.
• Autonomous Committee (art. 79): seven members, five of them independent experts.
• FONPET (arts. 80 and 81): specified budget obligations would be paid in ten equal instalments from 2027; other outstanding obligations at year-end 2026, in nine from 2028. Decree 444 of 2020 obligations retain agreed terms; recording only upon actual receipt, with possible acceleration for pension needs. Departments contribute 10% of unrestricted current revenue to the general-purpose sector.

Why it matters: these fiscal discipline rules aim to build confidence among investors and rating agencies.

Fiscal rule, article-specific qualifications

• Art. 72: net debt, 71% ceiling and 55% GDP anchor; four-year structural net primary balance (BPNE) targets, favourable CONFIS and non-binding CARF opinions, reference BPN* + 0.1 × (prior net debt minus 55). Ordinary decree before the initial government year's 15 December; 2027-to-2030 transition by 31 March 2027. Prior escape only 2025/2026; new activations/extensions under requirements and maximum three fiscal years. Debt from 63% to under 71% triggers personnel CPI plus 0.5-point and purchasing CPI ceilings; from 71%, broader adjustments and future-commitment limits with constitutional/social exceptions. These percentages do not establish predicted compliance.
• Art. 73: balance = prior balance plus observed BPNE minus minimum; starts in 2027 without deviations accumulating during escape.
• Art. 74: balance equal to or below minus 0.5% triggers adjustment by the following 31 March through bill and/or acts; further mechanisms if measures are not approved or fail to correct under deadlines, protecting rights/social expenditure.
• Art. 75: forecast deviation acknowledged by CONFIS is quantified/published with causes, timetable and impact; does not alter the target or constitute compliance.
• Art. 76: annual report to Congress by 31 March and public quarterly monitoring.
• Art. 77: minister explains failures to economic commissions with CARF president participation; no replacement for correction.
• Art. 78: expenditure consistency between fiscal/spending frameworks and July national budget proposal.
• Art. 79: seven members, five experts and two economic-commission presidents; experts from central-bank shortlists appointed by Finance for four years renewable once. Public non-binding opinions; 158 UVT per session, 190 for president, maximum twelve paid sessions. Information within ten working days extendible with justification.
• Arts. 80/81: distinct national payment schedules and 10% departmental contribution to general-purpose pensions, not all departmental budgets.

Title VI. Enforcement, DIAN and relief

Evasion and smuggling (articles 82 to 98)

• National policy and coordination (arts. 82 to 84): policy within six months; DIAN plan under the National Development Plan deadline, government-term validity and annual evaluation. Advisory committee with authorities and six trade representatives, twice-yearly ordinary sessions. Automated agreements with national/territorial public bodies, not general permission to override confidentiality or share with private parties.
• Smuggling offence (art. 85): for the specified conduct involving goods worth more than 25 minimum wages, prison of four to eight years and a fine of 200% to 300% of customs value. Above 100 minimum wages, prison of nine to twelve years with the same fine band. Aggravating circumstances apply and legalising the goods does not extinguish criminal prosecution.
• Crypto-assets (art. 86, new art. 21-2 Tax Code): legally represented underlying assets prevail, not mere price references. Without underlying assets, location rules do not exclude worldwide taxation. Acquisition/development cost and non-deducted expenses; weighted average for fungibles; tax-cost valuation and fluctuations on transfer/extinguishment without deferring realised returns.
• Indirect transfers (art. 87): listed-share exception under active secondary trading and no beneficiary concentration above 20% during twelve months. The other exception requires Colombian assets not above 20% of either book or commercial value during that period; not simply small transactions. Includes joint liability, returns and tokens representing domestic assets.
• Technology providers (art. 88): duties cover authorisation, generation, transmission, security, confidentiality, support, infrastructure, interoperability and fraud prevention, with distinct infringements. This article does not itself set fine rates.
• Fiscal prize (art. 89): free participation for individual purchasers identified on valid electronic documents, possibly automatic with verification; prizes would be neither income nor occasional gains. Reporting non-issuance requires verification and does not duplicate participation through a later document.
• Defective invoices (art. 90): 5% of irregularly invoiced operations, capped at 3,500 UVT; repeat conduct within two years of finality increases it to 7% without that ceiling. Independent assessment requires charges and ten days to respond.
• Failure to invoice (art. 91): the higher of 5% of own previous-month net income and 5% of the DIAN-published monthly median for the principal CIIU activity. Repeat conduct: 7%. No specific ceiling stated.
• Evidence record (art. 92): records in-person, virtual or evidenced infringement, facts and explanations; restricts later explanations differing from those recorded. Creates no additional fine.
• Closure (art. 93): three days for electronic suppression, double bookkeeping/invoicing and unrecorded documents; thirty for customs seizure under forfeiture, except proven good-faith holders; three for omissions or arrears over three months by listed liable persons, with pending requested-offset, filing/payment and proven defence exceptions; three for technical-control failures. Monetary replacement by ground: 10%, 15%, 15% or 10% of previous-month operating income. Breaking seals doubles duration after defence; residential access remains without business. Internet games under the fourth ground face blocking instead of closure. Accumulation or incompatibility is not presumed without analysing conduct and legal grounds.
• DIAN receivables (art. 94): DIAN could monetise, factor, securitise or assign economic rights over hard-to-collect tax, customs and foreign-exchange receivables, without transferring or relinquishing its assessment, dispute-resolution or collection powers.
• Imported fuels (art. 95): distinct from articles 99 to 104 relief. Returns through 31 December 2025, amount above 2,000,000 UVT, subsequent doctrine changes on essential tax elements and pending proceedings/lawsuit at commencement without final decision or fraud. The full favourable interpretation in force at the time would apply without combining doctrines; interest 4.5% annually, settlement of 85% of penalties or exemption under proven reasonable interpretation. Application within six months; allows offsets and plans up to ten years, over five with authorisation, security and special VAT rules. Includes forfeiture on default and specific declarant-agency treatment; not a general benefit for every importer.
• DIAN (arts. 96 and 97): six-month powers for the specific career/personnel system under Decree 927 of 2023; report to Congress one year after powers expire. Prioritisation by nature, amount, risk, age, recovery potential, capacity and opportunity cost; does not itself extinguish obligations or offences.
• Withholding agents (art. 98): criminal proceedings under Criminal Code article 402 would apply to conduct involving at least 159 UVT, assessed individually. Conduct below that threshold would not be reported for criminal prosecution, without prejudice to administrative collection.

Tax relief (articles 99 to 104)

The principal application and compliance deadline is 30 June 2027, but eligibility differs: articles 99 and 100 cover obligations in arrears at 30 September 2026; article 101 distinguishes omitted returns due by that date, corrections to returns filed by that date and formal breaches by that date; article 102 covers expired filing or payment deadlines or infringements committed by that date and requires the relevant DIAN notice before the law takes effect; article 103 requires a lawsuit filed by 30 September 2026, admitted before the settlement application and with no final judicial decision terminating the case. Payment plans and certain steps may continue after 30 June: DIAN would have until 31 August 2027 to decide timely article 102 applications, and judicial approval under article 103 may occur later.

Relief covers large taxpayers. Special reductions cannot be stacked on the same penalty or interest or combined with Legislative Decree 1419 of 2026 for the same tax obligations. Article 99 plans may cover obligations benefiting from other chapter measures. Payments before commencement do not create refunds, offsets or credit balances through these benefits (art. 104). Minimum penalties must be respected. Article 100 excludes offsets and account netting as payment methods on its terms. Article 101 also includes specified formal and foreign-exchange breaches and customs corrections for very serious infringements.

Further verified relief conditions: article 99 includes insolvency administrative expenses and decides complete applications within two months; default restores general penalties/rates on defaulted obligations without reopening accepted facts. Article 100 limits payment methods, covers outstanding prior-plan balances and judicial deposits constituted by 30 September 2026; minimum penalty from its assessment year. Article 101 includes transfer-pricing, foreign-exchange/formal duties, combination with Tax Code reductions without going below the minimum and customs exceptions; administrative disputes require no notified appeal decision, acceptance and repayment. Article 102 requires pre-commencement notices; 60% reduction/40% paid, full capital where applicable and interest, correction and separate autonomous-penalty/non-filing/refund requirements; available while administrative proceedings remain pending or, once concluded, while the deadline to sue has not expired. If a lawsuit has already been filed, it must not have been admitted and its withdrawal must be evidenced before signing the agreement. Finality or expiry of the litigation deadline after a timely application does not justify rejection; the application does not suspend appeal or litigation deadlines. Article 103: applications by June, decision within one month after submission of the complete application, record to judge within ten working days, approval may be later; 2026 private tax paid if due, no final decision and exclusion of goods' legal-status proceedings. Article 104 does not prohibit plans alongside another relief measure or expressly allowed Tax Code penalty reductions.

Title VII. Final provisions (articles 105 and 106)

Article 105 identifies the organic provisions. Article 106 makes the law effective upon enactment and repeals, among others: exempt income under items 7 and 9 of article 206 Tax Code, article 243 Tax Code, the single-use plastics tax, the 5% VAT rates (from 2028), several VAT exclusions, the non-taxable inflationary component of financial yields and older smuggling rules.

Commencement and nine repeal groups (art. 106)

Unless a specific rule applies, from promulgation: (1) income tax, items 7/9 of Tax Code article 206, second paragraph of item 3 of article 336 and article 243; (2) plastics, articles 50 to 53 of Law 2277/2022 and item 11 of Tax Code article 643; (3) penalties, paragraph 2 of 616-1, paragraphs 1/2 of 617, last two paragraphs of 837-1; (4) VAT, item j of 428, 465, headings 85.01, 85.07, 85.04, 87.02, 87.03, 87.04, 87.05, 87.06, 87.07, 87.11, 87.12, 90.31 and 90.32 and item 2 of 468-1, items 20/21 of 476, items d/h of 481, article 108 Law 633/2000 and article 33 Law 1816/2016; complete articles 468-1 and 468-3 only from 1 January 2028; (5) inflationary component, articles 38, 39, 40 and 40-1; (6) smuggling, articles 147 to 155 and 158 Law 223/1995, article 146 Law 1607/2012 and article 31 Law 1762/2015; (7) consumption tax, fourth paragraph with items 1/2 and paragraphs 1/2 of 512-2; (8) assets, article 238 Law 1450/2011 amended by article 330 Law 2294/2023; (9) tourism, article 6 Law 1101/2006.

Article 105 lists organic provisions: articles 2, 3, 6, 10, 16, 17, 37, 60, 61, 62, 63, 64, 72, 74, 75 and 78, not the entire initiative.

Points in the bill itself requiring clarification

1. Rice (arts. 42/46): heading 10.06 for human consumption appears both excluded and exempt. No definitive classification is editorially chosen.
2. Fuels (arts. 42 to 44): generally effective bases refer to new 2028 rules; retail bases/liability require alignment. No single commencement date is asserted for all measures.
3. Tables (arts. 48/50): constants cause small bracket discontinuities. Printed constants are reproduced, not intuitively corrected.
4. Contributions (arts. 20/21): individual-employer exemptions for two to five workers require alignment with salary ceilings; special-regime increments do not establish unequivocal resulting total rates here.
5. Territory (arts. 42/46): an incomplete human/animal consumption phrase and Amazonas end-use/corporate purchaser conditions require alignment. No blanket purchaser benefit is inferred.
6. RUGE (new art. 922): some ranges/default consequences are not equally developed; no solution is invented for unaddressed cases.
7. Cross-references: article 55 cites Law 1819 of 2019 while 53/54 cite 2016; article 40 includes references needing coordination. References to 2026 laws/decrees are identified as bill references, not externally certified merely because cited.

Precision includes distinguishing clear rules from legislative ambiguity. These observations neither establish legal invalidity nor predict congressional outcomes.

Points to review now

Since the text may change during debate, the prudent approach is to work with scenarios and update them at each stage:

1. Companies: estimate the 2027 and 2028 effective rate, with and without the contribution exemption, together with the VAT classification of their products from 2028.
2. Investment projects: check whether they would meet RUGE thresholds and requirements and how the execution start date would affect them.
3. Individuals: review their income composition and net worth as of 1 January 2027.
4. Omitted assets or crypto-assets: understand the conditions and effects of the normalisation planned for 2027.
5. Pending DIAN obligations: identify which could qualify for relief and the applicable deadlines.
6. Monitoring: update these analyses after each debate.

At T&C we are following the bill's progress. If you would like to review how it could apply to your case, our team can assist.