The Estatuto Tributario (Decree 624 of 1989) runs to more than a thousand articles. These pages translate in full the articles a foreign investor actually needs, grouped by topic, with the Spanish original under every paragraph and notes on amendments and Constitutional Court rulings.
Tax residence and place of effective management, Colombian-source income, the 35% rate, sector surcharges, the 15% minimum tax (TTD), free trade zones.
Arts. 30, 48, 49, 242, 242-1, 245, 246, 246-1, 254-1DividendsUntaxed and taxed profits, 10% between Colombian companies, 20% for foreign shareholders and permanent establishments, resident individuals.
Arts. 20-1, 20-2, 20-3Permanent establishment and significant economic presenceThe PE definition, taxation of branches and PEs, and SEP for non-residents selling goods and digital services to Colombia.
Arts. 894–898Colombian Holding Companies (CHC)Requirements and substance, exempt foreign dividends and gains, foreign-source treatment for non-resident shareholders.
Arts. 260-1 to 260-11Transfer pricingRelated parties, arm’s length methods, local file, master file, country-by-country report, informative return, APAs, penalties.
Arts. 420, 421, 429, 437, 437-1, 437-2, 468, 468-1, 468-3, 481, 485, 489Value added tax (IVA)Taxable events, services from abroad, persons liable, reverse charge and card withholding, 19% and 5% rates, exports.
Arts. 903–916Simple Tax Regime (Régimen Simple)The optional unified tax for businesses owned by Colombian residents: eligibility, exclusions, rates by activity, payments.
Arts. 25, 121–124-2, 406–419, 592Withholding tax on payments abroadThe 20% rate on services, royalties and interest, 15% on loans, 33% on management fees, 10% on SEP sellers, low-tax jurisdictions, deductibility of payments abroad.
Arts. 555-2, 591, 684–734, 817, 818, 854, 869–869-2Tax procedure: audits, appeals and tax abuseRUT, audit powers, the special requirement, finality of returns, reconsideration, refunds, limitation of collection, the anti-abuse rule.
Arts. 634–651, 658-1, 658-3Penalties and default interestDefault interest, minimum penalty and reductions, late filing, failure to file, corrections, inaccuracy, information returns, RUT penalties.
The texts reflect the Statute as amended by Law 2277 of 2022 and later changes recorded in the DIAN legal compilation. The emergency tax decrees of December 2025 (Decrees 1390 and 1474 of 2025) were struck down by the Constitutional Court in 2026. A reform bill, No. 004 of 2026 in the House of Representatives, was filed on 20 July 2026 and was in committee in October 2026; it would, among other things, raise the dividend rate for non-residents from 20% to 30%, the optional rate for significant economic presence from 3% to 5% and the financial-sector surcharge to 15 points. Each page says what the bill would change in its articles. Separately, Legislative Decree 1419 of 2026, issued under the economic emergency declared after the earthquake of 10 August 2026, temporarily reduces penalties and default interest on obligations in arrears before that date (applications by 19 November 2026); see Penalties and default interest.
Each topic page has a short summary, our commentary, the full English text with the Spanish under every paragraph, and a list of the acts that gave the articles their current wording. Article anchors follow the Statute’s numbering: #art-240, #art-20-3, #art-260-5; paragraph anchors add -p1, -p2 or -pu.
Unofficial translations for information. Only the Spanish text published in the Diario Oficial is authentic. Nothing here is tax advice.
Corporate tax, dividends, PE, VAT or transfer pricing: we work from the Statute. Fixed quote within one business day.
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