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Colombia: Tax proposals in Finance Bill

International taxation, corporate income tax, VAT, and e-invoicing proposals

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September 10, 2025

The Colombian Treasury Department on September 1, 2025, released a Finance Bill that proposes changes to tax legislation concerning:

  • International taxation
    • Significant economic presence
    • Permanent establishment
    • Tax on dividends distributed to nonresidents
    • Corporate income tax rules applicable to digital assets
    • Indirect transfer of assets rule
    • Effective seat of administration (ESA)
    • Authorization of the change of foreign shareholders
    • Transfer pricing and corporate income tax rules interaction
  • Corporate income tax and capital gains tax
    • Corporate income tax surcharge
    • Capital gains tax
    • Cash payments
    • Non-deductible expenses
    • Income from asset comparison
  • Net worth tax
    • Taxable event
    • Rate
  • Consumption tax
    • Taxable event
    •  Rate
    • Beer and mixed drinks
    • Liquors, wines, aperitifs, and similar items
    • Cigarettes, manufactured tobacco, derivatives, substitutes, or imitations
  • Value added tax (VAT)
    • Taxable event
    • Elimination of VAT exclusions
    • Rate
  •  Environmental and healthy taxes
    • Investment in non-conventional energy sources (NCEs)
    • National carbon tax
    • Special tax on the extraction of hydrocarbons and coal
  • Other relevant proposals
    • Electronic invoicing
    • Automatic exchange of information framework
    • Special statute of limitations
    • Deadlines for correcting returns
    • General anti-abuse rule (GAAR) procedure
    • Temporary reduction in penalties and interest

KPMG observation

The bill is expected to have a low chance of being passed by Congress.

Read a September 2025 report prepared by the KPMG member firm in Colombia

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