What does Colombia's Economic Rescue Bill propose for companies, and what should the parent company know?

Is any of this in force?

No. This is the text the government submitted to Congress, and it has not yet had a committee report or a first vote. To become law, it must pass the committees and the full House and Senate, and then be signed. Any article can be changed, dropped or added along the way.

According to a timeline anticipated by a member of Congress and reported by Actualícese, a Colombian tax publication, the economic committees of both chambers would meet jointly in the second half of November, with floor votes in early December. Congress's first regular session period ends on December 16. If the bill has not passed by then, the government could call extraordinary sessions, or the process would resume on March 16, 2027.

The timing matters. Under article 338 of Colombia's Constitution, changes to taxes assessed by period, such as income tax, apply from the period that starts after the law takes effect. So the income tax rates proposed for 2027 depend on the law being enacted in 2026.

Until the bill becomes law, current rules apply. Everything below describes the text as filed on October 29. If Congress changes it, we will update this article.

What does it propose for the corporate income tax rate?

Article 57 of the bill lowers the general rate:

The UVT is Colombia's tax value unit, updated every year (COP 52,374 in 2026).

What changes in the 15% minimum tax?

Today, Colombia's minimum tax (tasa de tributación depurada) applies broadly to companies that pay income tax, with some exceptions. If the tax falls below 15% of adjusted book profit, the company pays the difference.

The bill keeps the formula but applies it only to:

• The parent entity of a multinational group resident in Colombia.
• Colombian subsidiaries, branches or permanent establishments of a multinational group, whether Colombian or foreign.

In both cases, only when the group had consolidated revenue of EUR 750 million or more in the previous year, based on the parent entity's financial statements. For foreign groups, the threshold is measured in the currency of the parent entity's country, at the average exchange rate for the previous December.

What changes in payroll costs?

Today, under article 114-1 of the Tax Code, companies that file income tax do not pay the training (SENA) and family welfare (ICBF) payroll taxes, or the employer's health contribution, for employees earning less than 10 monthly minimum wages. Articles 20 and 21 of the bill propose, from January 1, 2027:

For each employee earning over 3 and under 10 minimum wages, the company would pay 13.5% of salary in contributions it does not pay today: 2% SENA, 3% ICBF and 8.5% health. For those earning over 2 and up to 3, it would pay 6%.

The employee's health contribution would change too. Today employees pay 4%. The bill keeps 4% up to 2 minimum wages and raises it by bracket: 5.5% for over 2 and up to 4 minimum wages, 6% for over 4 and up to 5, 6.5% for over 5 and up to 10, 7% for over 10 and up to 15, 7.5% for over 15 and up to 20, and 8% for over 20 and up to 25. The employer's rate stays at 8.5%, subject to the full or partial relief in the table.

And wage withholding. The table in article 50 of the bill starts withholding above 65 UVT of monthly taxable labor income, at 9% in the first bracket. Today withholding starts above 95 UVT, and the first rate is 19%. The 39% rate would apply to income above 640 UVT a month; today it applies above 2,300 UVT. For employees earning over 2 minimum wages, these changes lower take-home pay. For the company, they change how payroll is calculated.

What this means for the parent company

Three points to model as 2027 budget scenarios:

• A lower income tax rate: 33% in 2027 and 31% from 2028, if the law is enacted in 2026.
• The minimum tax depends on group size. If the group's consolidated revenue is EUR 750 million or more, the Colombian subsidiary would keep calculating it. Below that, it would stop.
• Higher payroll costs for employees earning over 2 minimum wages.

For large new investments, the bill also creates a stability regime (Régimen Único para Generar Estabilidad Empresarial, RUGE): a 20% or 26% income tax rate, an 8% tax on dividends paid to foreign shareholders, and 16 years of stability. Its conditions matter before running the numbers:

• It works through a new company or branch dedicated only to the project. An existing subsidiary with other activities cannot use it directly.
• The rate depends on the year the project is registered: 20% for 2027 or 2028, and 26% from 2029. Applications could be filed through December 31, 2029.
• Minimum investment is 2,580,000, 5,530,000 or 8,140,000 UVT depending on the sector, and commerce, financial and real estate activities, among others, are excluded.
• Commitments: buying at least 30% of the project's goods and services from Colombian suppliers, a performance guarantee of at least 2% of the committed investment, and an annual fee to the government of 0.1% of the investment made.

What else does it propose for companies?

• VAT: from 2028, it repeals the articles that today tax some goods and services at 5%, and changes the lists of excluded goods and services (outside VAT, with no input credit) and exempt ones (zero-rated). Other changes would apply once the law is enacted, such as the general VAT rate on liquor and on games of chance operated exclusively online.
• DIAN relief: for obligations past due on September 30, 2026, a company would pay by June 30, 2027 100% of the tax, interest at 5% a year and 40% of the penalties. It also covers unfiled or incorrect returns, with payment plans of up to 12 months.
• Individual income tax: the new table taxes income above 720 UVT a year (today, above 1,090) and lowers some caps on exempt income.
• Tax normalization in 2027: a one-time 15% tax to regularize undeclared assets or nonexistent liabilities as of January 1, 2027.
• Excise taxes: changes the rates on liquor, cigarettes and beer, the carbon tax and, from 2028, the tax on ultra-processed drinks.
• Invoicing: changes the penalties for not invoicing, for invoices that miss requirements, and for business closure.

On the DIAN relief, one point. The bill says it cannot be combined with the relief under Legislative Decree 1419 of 2026 for the same obligations. Decree 1419 is in force: according to the DIAN, for obligations past due on August 10, 2026, it allows penalties to be paid at 15% and interest at 4.5% a year until November 19, 2026. We explain it here.

What to do with this

1. Keep applying current rules while it is a bill: payroll, withholding and taxes are calculated as they are today.
2. If your subsidiary has DIAN debts past due on August 10, 2026, review Decree 1419 before November 19, since it is the rule in force today.
3. Run two payroll scenarios for 2027, with today's relief and with the bill's, especially for employees earning over 2 and under 10 minimum wages.
4. Check the group's consolidated revenue to see whether the minimum tax would still apply to the Colombian subsidiary.
5. Follow the bill: the committee report and the votes can change any of these points.

Sources

• Bill 477 of 2026 (House), "Por la cual se expide la Ley de Rescate Económico…", text filed with the General Secretariat of the House of Representatives on October 29, 2026, arts. 20, 21, 27 to 36, 41 to 50, 53 to 57, 69, 70, 90 to 93, 99 to 104 and 106.
• Actualícese, "Implicaciones del proyecto de Ley de Rescate Económico para contadores, empresarios y contribuyentes," October 30, 2026 — actualicese.com
• Colombian Tax Code in force, arts. 114-1, 206, 240, 241, 336, 383, 468-1 and 468-3 — Senate General Secretariat
• Law 100 of 1993, art. 204, health contributions
• Colombian Constitution, arts. 138 and 338
• Legislative Decree 1419 of 2026 — DIAN regulatory database · DIAN press release 133 of 2026 — dian.gov.co
• 2026 UVT: DIAN Resolution 000238 of 2025 — DIAN regulatory database