Colombia bill proposes 16-year tax stability regime for major investments

Dedicated vehicle and new assets

Article 69 would add a new Book Nine to the Tax Statute for the Régimen Único para Generar Estabilidad Empresarial, or RUGE. It would be open to domestic and foreign investors using a new Colombian company or Colombian branch of a foreign company formed exclusively for the project and without operating income when it applies. Eligible investment would generally comprise new, or previously unused in Colombia, depreciable or amortisable fixed assets that increase productive capacity. Existing businesses or shares, reorganisations, related-party asset transfers, land and working capital would not count.^[1][2]

Sector thresholds and application period

The minimum committed investment would depend on sector: 8.14 million UVT for infrastructure, energy and natural-resources projects; 5.53 million UVT for industry and specified digital activities; and 2.58 million UVT for agroindustry, tourism, services and other eligible activities. Commerce, financial and insurance, real-estate and certain public or extraterritorial activities would be excluded. Applications could generally be made until 31 December 2029, with a 16-year stability period; public-private partnership applications could run until 31 December 2031 under separate rules.^[2]

Proposed tax and customs incentives

For a certified project starting execution in 2027 or 2028, the project vehicle's income-tax rate would be fixed at 20%; projects starting from 2029 would receive a 26% rate, without surcharges or additional points. Qualifying profits distributed to non-resident shareholders would face an 8% final withholding tax. The proposal also permits accelerated depreciation of up to 50% annually for specified equipment and 10% for buildings, exempts the project vehicle from national wealth taxes, and authorises temporary customs treatment for eligible capital goods. RUGE could not be combined with free-zone, ZOMAC, ZESE or specified exempt-income regimes.^[2]

Measurable commitments

The vehicle would have to execute at least 40% of committed investment within two years and complete it within the sector's five-to-eight-year period; source at least 30% of relevant purchases from national suppliers, with one-third of that amount directed to smaller or local suppliers; provide a guarantee of at least 2% of committed investment; and report progress annually. Applications would go electronically to the Ministry of Commerce, Industry and Tourism.^[2]

Proposal, not available relief

Bill 477/2026C is an ordinary bill published in Gazette 1717 of 2026, with no Senate number shown on the Chamber record. Groups considering Colombian expansion should model a separate project vehicle, sector classification, UVT threshold and procurement commitments, but must not rely on any benefit before enactment, certification and implementing regulations. This focused brief does not complete review of the wider Economic Rescue package.^[1][2]