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Tax incentives in Colombia: free trade zones, R&D credits, ZOMAC, ZESE, tourism rates and the holding company regime

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Last verified: 2026-10-26 · Status: Stable

Colombia's main tax incentives for investors are the 20 percent rate on export income for free trade zone industrial users that sign an annual internationalization plan, a 30 percent credit for qualified R&D investment, reduced rates to 2027 for new companies in conflict affected ZOMAC municipalities, 15 percent rates for qualifying hotels and ecotourism, and the CHC holding company regime with exempt foreign dividends. The ZESE regime closed to new entrants at the end of 2024 and Ley 2277 de 2022 repealed mega investment contracts, keeping benefits already acquired.

USD figures use the TRM of COP 3,158.43 per US dollar, valid 24 to 26 October 2026, from the official TRM series certified by the Superintendencia Financiera and published on datos.gov.co. UVT amounts use the 2026 UVT of COP 52,374 (DIAN Resolución 000238 de 2025). Conversions are for orientation only.

Key facts

Income tax rate for free trade zone industrial users on the export share of income	20 %Estatuto Tributario art. 240-1, as of 2026-10-26 · in force
Tax credit for qualified R&D and innovation investment	30 % of investmentEstatuto Tributario art. 256, as of 2026-10-26 · in force
Cap on R&D, environmental and donation credits, share of income tax	25 %Estatuto Tributario art. 258, as of 2026-10-26 · in force
ZOMAC new micro and small companies, share of the general rate, 2025 to 2027	50 % of general rateLey 1819 de 2016 art. 237 lit. a, as of 2026-10-26 · in force
ZOMAC new medium and large companies, share of the general rate, 2022 to 2027	75 % of general rateLey 1819 de 2016 art. 237 lit. b, as of 2026-10-26 · in force
Last date to enter the ZESE regime	2024-12-31 dateLey 2277 de 2022 art. 96, as of 2026-10-26 · in force
Minimum stake in two or more companies for the CHC holding regime	10 %Estatuto Tributario art. 894, as of 2026-10-26 · in force
UVT for 2026	52374 COPDIAN Resolución 000238 de 2025, as of 2026-10-26 · in force
TRM used for USD conversions (valid 24 to 26 October 2026)	3158.43 COP per USDOfficial TRM series, Superintendencia Financiera de Colombia, as of 2026-10-24 · in force

The rule

1. Free trade zone industrial users pay 20 percent income tax on the share of net taxable income corresponding to exports of goods and services (export income over total tax income, excluding occasional gains) and the general 35 percent on the rest. To apply the 20 percent they must agree an internationalization and annual sales plan with the Ministerio de Comercio, Industria y Turismo for each tax year, setting maximum income from the national customs territory; if they do not sign or miss the targets, the whole income is taxed at 35 percent. Commercial users pay the general rate. Offshore free zones, port service users, special free zones for refining fuels or industrial biofuels, logistics service users and zone operators pay a flat 20 percent.
Example: An industrial user with net taxable income of COP 1,000,000,000, 60 percent from exports: 20 percent on COP 600,000,000 = COP 120,000,000 plus 35 percent on COP 400,000,000 = COP 140,000,000; total COP 260,000,000 instead of COP 350,000,000. / About US$316,613 of income: about US$82,319 of tax instead of US$110,815.Estatuto Tributario (Decreto 624 de 1989), as amended by Ley 2277 de 2022 art. 11, Art. 240-1, num. 1 to 3, par. 1, 5 and 6, 2022-12-13 official text · verified 2026-10-26

2. Taxpayers investing in projects qualified by the national council for science, technology and innovation tax benefits as research, technological development or innovation may credit 30 percent of the amount invested against income tax in the year of investment; the same applies to some donations to scholarship programmes and iNNpulsa and to the salaries of PhD holders hired for R&D. Investments may be made through actors recognised by the Ministry of Science, and an annual global cap is approved by CONFIS. Together with the environmental and donation credits, these credits may not exceed 25 percent of income tax in the year, with the excess carried forward four years.
Example: Qualified R&D investment of COP 500,000,000: credit of COP 150,000,000, usable up to 25 percent of the year's income tax. / About US$158,307 invested: credit of about US$47,492.Estatuto Tributario, art. 256 as amended by Ley 2277 de 2022 art. 21; art. 258 as amended by Ley 1819 de 2016 art. 106, Art. 256, first paragraph, par. 2 and 4; art. 258 num. 2, 2022-12-13 official text · verified 2026-10-26

3. New companies with their main domicile and all their activity in the municipalities most affected by the armed conflict (ZOMAC) that meet minimum investment and employment requirements pay reduced income tax: micro and small companies 50 percent of the general rate for tax years 2025 to 2027, and medium and large companies 75 percent of the general rate for tax years 2022 to 2027; from 2028 the general rate applies.
Example: A small ZOMAC company with net taxable income of COP 200,000,000 in 2026: rate 17.5 percent, tax COP 35,000,000 instead of COP 70,000,000. / About US$63,323 of income: about US$11,081 of tax instead of US$22,163.Ley 1819 de 2016, Art. 237, lit. a and b, 2016-12-29 official text · verified 2026-10-26

4. The Special Economic and Social Zone (ZESE) regime for La Guajira, Norte de Santander, Arauca and capital cities with unemployment above 14 percent gives 0 percent income tax for five years from incorporation and 50 percent of the general rate for the next five years to qualifying industrial, agricultural, commercial, tourism or health companies that carry out all their activity in the zone (excluding ports, mining and hydrocarbons). Entry into the regime was available only until 31 December 2024; companies that qualified keep the benefit for its full term.Ley 1955 de 2019 art. 268, as amended by Ley 2010 de 2019 art. 147; Ley 2277 de 2022 art. 96, Ley 1955 art. 268 (first to fourth paragraphs, par. 3 and 5); Ley 2277 art. 96, 2022-12-13 official text · verified 2026-10-26

5. Reduced 15 percent income tax rates apply for ten years to qualifying new or remodelled hotels, ecotourism theme parks and agrotourism projects in municipalities of up to 200,000 inhabitants or PDET municipalities, and to book publishers (see taxes/corporate-income-tax).Estatuto Tributario, as amended by Ley 2277 de 2022 art. 10, Art. 240, par. 5 and 7, 2022-12-13 official text · verified 2026-10-26

6. Colombian holding companies (CHC) with at least 10 percent stakes in two or more Colombian or foreign companies for at least 12 months, at least three employees, their own address in Colombia and strategic decisions taken in Colombia, that notify DIAN, receive foreign dividends exempt from income tax; dividends they pay to non residents are foreign source income, and gains on selling foreign subsidiaries are exempt occasional gains. The benefits do not apply to recipients in non cooperative or low tax jurisdictions.Estatuto Tributario, as amended by Ley 2010 de 2019 art. 77, Art. 894, 895, 896 and 898, 2019-12-27 official text · verified 2026-10-26

7. Companies that file income tax returns are exempt from SENA and ICBF payroll levies and from the employer health contribution for employees earning less than 10 minimum wages (see taxes/payroll-taxes).Estatuto Tributario, added by Ley 1819 de 2016 art. 65, Art. 114-1, 2016-12-29 official text · verified 2026-10-26

8. Ley 2277 de 2022 repealed, among others, the mega investment regime (art. 235-3 and 235-4) and several exempt income items of art. 235-2, but taxpayers that had met the conditions for repealed or limited benefits keep them for the full term granted by the law under which they qualified.Ley 2277 de 2022, Art. 96, 2022-12-13 official text · verified 2026-10-26

9. Several benefits (including some exempt income, special deductions and tax credits listed in art. 259-1) are capped together at 3 percent of ordinary net income; R&D credits under art. 256 and free trade zone rates are not in that list.Estatuto Tributario, added by Ley 2277 de 2022 art. 14, Art. 259-1, last paragraph, 2022-12-13 official text · verified 2026-10-26

Incentive	Benefit	Key conditions	Norm
Free trade zone industrial user	20% on the export share of income	Annual internationalization plan with MinCIT	Art. 240-1
R&D and innovation	30% tax credit	Project qualified by the national council; 25% of tax cap	Art. 256, 258
ZOMAC new companies	50% (small) or 75% (medium, large) of the general rate to 2027	Domicile and all activity in a ZOMAC municipality; investment and jobs	Ley 1819 art. 237
ZESE	0% for 5 years, then 50% for 5 years	Entry closed on 31 December 2024; existing beneficiaries only	Ley 1955 art. 268; Ley 2277 art. 96
Hotels, ecotourism, agrotourism	15% for 10 years	Municipalities up to 200,000 inhabitants or PDET; built within the five year window	Art. 240 par. 5
Colombian holding company (CHC)	Foreign dividends and gains exempt; outbound dividends foreign source	10% stakes in 2+ companies for 12 months; substance in Colombia	Art. 894 to 898
Payroll exemption	No SENA, ICBF or employer health under 10 minimum wages	Income tax filer	Art. 114-1

Main income tax incentives open to foreign investors in Colombia on 26 October 2026

Worked example

A manufacturer in a free trade zone exporting 60 percent of its income pays 26 percent overall (20 percent on the export share and 35 percent on the rest) if it signs and meets its annual internationalization plan; otherwise 35 percent on everything.
A Colombian holding company that owns subsidiaries in Peru and Mexico can receive their dividends tax free and pay them on to its foreign shareholders as foreign source income, if it has three employees and takes strategic decisions in Colombia (art. 894 and 895).

Step by step

Check the investment's location (ZOMAC municipality, free trade zone, PDET municipality) and sector before choosing the entity.
For free trade zones, sign the internationalization and annual sales plan with MinCIT for every tax year (art. 240-1 par. 6).
For R&D credits, get the project qualified before investing and track the 25 percent annual cap (art. 256 and 258).
For the CHC regime, notify DIAN and build real substance in Colombia: three employees, own address, decisions taken locally (art. 894).
Run the 15 percent minimum tax test: some incentives reduce tax below the floor and trigger a top up (art. 240 par. 6).

Common traps

Free trade zone users that do not sign the annual plan or exceed the domestic sales cap lose the 20 percent rate for the year (art. 240-1 par. 6).
ZESE is closed to new companies since 31 December 2024 (Ley 2277 de 2022 art. 96).
ZOMAC reduced rates end after tax year 2027 (Ley 1819 de 2016 art. 237).
The R&D credit is capped at 25 percent of income tax each year together with environmental and donation credits (art. 258).
CHC benefits do not apply if the shareholder is in a non cooperative or low tax jurisdiction (art. 895 par.).

Sources

Related: Colombia country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

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