Colombian Corporate Income Tax and the 15% Minimum Tax: A Guide for Foreign-Owned Companies

35% corporate tax, sector surcharges, the 15% minimum tax, filing instalments, and the second layer when profits go home.

Figures verified 7 October 2026 · Applies to: AG2025 / 2026 rules

A foreign-owned Colombian company pays the same corporate income tax as any Colombian company. For investors used to lower headline rates elsewhere, the numbers deserve a careful look, and so does the 15% minimum tax that has applied since Ley 2277 of 2022.

The general rate: 35%

Colombia’s general corporate income tax rate is 35%, unchanged for 2026. Some sectors pay more:

  • Financial institutions with taxable income of 120,000 UVT or more: an extra 5 points, for 40% (2023–2027).
  • Hydroelectric generation: an extra 3 points, for 38% (2023–2026).
  • Crude oil and coal extraction: additional points that depend on international price levels.

Companies file on Formulario 110.

The 15% minimum tax (tasa mínima de tributación)

Ley 2277 introduced a floor. If a company’s tax, measured against its financial (book) profit with specific adjustments, works out below 15%, it pays a top-up to bring it to 15%.

Who it affects in practice:

  • Companies with large exemptions, deductions or incentives that bring taxable income well below book profit.
  • Companies relying on special regimes, where the benefit may be partly clawed back by the floor.

For an ordinary operating SAS paying 35% on a taxable profit close to its book profit, the minimum tax usually does not bite. It still has to be calculated, because the test is part of the return.

When profits go home: the second layer

Corporate tax is only the first layer for a foreign owner. Dividends paid to a non-resident shareholder carry 20% withholding, which makes the effective tax on distributed profit 48%. Profits distributed without having borne corporate tax are equalised by a separate rule, so incentives at the company level generally don’t survive distribution. The full arithmetic is in why 20% costs you 48%.

What else lands on the corporate tax return

  • Withholding already suffered. Customers who are withholding agents deduct tax from payments to the company during the year (for example 4% on services or 2.5% on purchases). Those amounts are credited against the annual tax.
  • Self-withholding, including the special self-withholding linked to the payroll exoneration.
  • Instalments. Companies pay their tax in instalments on DIAN’s calendar, not as a single payment.
  • Payments abroad. Deductibility of payments to related parties abroad depends on withholding and documentation. See withholding tax on payments abroad.
  • Transfer pricing. Companies with related-party transactions abroad must file transfer-pricing returns if gross assets exceed 100,000 UVT or income exceeds 61,000 UVT.

Filing calendar

For the AG2025 return, filed in 2026, ordinary companies filed and paid the first half between 12 and 26 May 2026, with the second instalment between 9 and 23 July. Large taxpayers (grandes contribuyentes) paid in three instalments from February to June. The calendar for the AG2026 return will be set by DIAN decree. Diarise it as soon as it is published.

What the 2026 reform bill would change

The tax bill filed on 20 July 2026 (Proyecto de Ley 004 of 2026) proposes a permanent higher rate for the financial sector and an increase in non-resident dividend withholding from 20% to 30%. It is a bill, not law. A new government took office on 7 August 2026 and the text may change. For the full story of what is and isn’t in force, see Colombia’s 2026 tax changes.

The Régimen Simple question

Smaller Colombian companies can sometimes opt into the simplified regime (Régimen Simple), which replaces income tax with a consolidated tax on gross income. Foreign-owned companies generally cannot. See can a foreign-owned company use the Régimen Simple?

Talk to us

The Colombian Accountant helps foreign investors and residents with Colombian tax returns, company formation and ongoing compliance, in English. Get your fixed quote.


This article is general information, not tax or legal advice. Colombian tax law changed materially between December 2025 and September 2026, and some rules described here are subject to pending legislation or litigation. Confirm your situation with a professional before acting.

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