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Colombia's tax treaties: 13 bilateral conventions in force, Andean Decision 578 and the treaty rates on dividends, interest and royalties

Argentina. For full detail on Argentina, go to The Argentine Thread.

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

Colombia has 13 bilateral income tax conventions in force according to DIAN, including Spain, Chile, Mexico, Canada, the United Kingdom, France, Italy and Japan, plus Andean Decision 578 with Bolivia, Ecuador and Peru. Treaties can cut the 20 percent dividend withholding to 0 or 5 percent for qualifying parent companies and cap interest and royalties at around 10 percent. Conventions with Brazil, the Netherlands, Luxembourg, Uruguay and the UAE are not yet in force, and there is no income tax treaty with Argentina or the United States.

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

Bilateral income tax conventions in force (DIAN list), excluding Decision 578 and the Pacific Alliance pension agreement	13 conventionsDIAN list of international tax conventions, as of 2026-10-26 · in force
Conventions listed by DIAN as not in force	Brazil, Luxembourg, Netherlands, United Arab Emirates, Uruguay DIAN list of international tax conventions, as of 2026-10-26 · in force
Income tax convention with Argentina	none (air and sea navigation agreement only) DIAN list; Ley 15 de 1970, as of 2026-10-26 · in force
Spain treaty dividend cap, company holding at least 20 percent	0 %Ley 1082 de 2006, convention art. 10, as of 2026-10-26 · in force
Chile treaty dividend cap, company holding directly at least 25 percent	0 %Ley 1261 de 2008, convention art. 10, as of 2026-10-26 · in force
United Kingdom treaty dividend cap, company holding directly at least 20 percent	5 %Ley 1939 de 2018, convention art. 10, as of 2026-10-26 · in force
Mexico treaty: Colombian tax on dividends to Mexican residents	0 % (residence only)Ley 1568 de 2012, convention art. 10, 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. DIAN lists income tax conventions in force with Spain (from 23 October 2008, Ley 1082 de 2006), Chile (22 December 2009, Ley 1261 de 2008), Switzerland (1 January 2012, Ley 1344 de 2009), Canada (12 June 2012, Ley 1459 de 2011), Mexico (11 July 2013, Ley 1568 de 2012), Korea (3 July 2014, Ley 1667 de 2013), India (7 July 2014, Ley 1668 de 2013), Portugal (30 January 2015, Ley 1692 de 2013), the Czech Republic (6 May 2015, Ley 1690 de 2013), the United Kingdom (13 December 2019, Ley 1939 de 2018), Italy (7 October 2021, Ley 2004 de 2019), France (1 January 2022, Ley 2061 de 2020) and Japan (4 September 2022, Ley 2095 de 2021), plus Andean Community Decision 578 (from 1 January 2005) and a Pacific Alliance agreement on pension funds (2 July 2023, Ley 2105 de 2021). Conventions with Luxembourg, Brazil, the Netherlands, Uruguay and the United Arab Emirates are listed as not in force.
Cost to do it: No fee to claim treaty benefits; the cost is obtaining residence certificates and supporting the beneficial owner position.Conventions approved by law and DIAN list of international tax conventions, DIAN list, section on conventions to eliminate double taxation on income, 2023-07-02 official text · verified 2026-10-26

2. Spain: dividends paid by a Colombian company to a Spanish resident beneficial owner may be taxed in Colombia at no more than 5 percent, or 0 percent if the beneficial owner is a company holding at least 20 percent of the capital directly or indirectly; interest at no more than 10 percent, and only in Spain for interest to the state, on credit sales of goods or equipment, or on bank loans; royalties at no more than 10 percent.
Example: Dividend of COP 315,843,000 to a Spanish parent holding 25 percent: Colombian tax 0 instead of COP 63,168,600 under art. 245. / US$100,000 of dividend: no Colombian withholding instead of US$20,000.Ley 1082 de 2006 (approves the Colombia Spain convention), Convention art. 10 (2), art. 11 (2) and (3), art. 12 (2), 2006-07-31 official text · verified 2026-10-26

3. Chile: dividends at no more than 0 percent where the beneficial owner is a company holding directly at least 25 percent of the capital, and 7 percent otherwise; interest at no more than 5 percent for banks and insurers and 15 percent in other cases; royalties at no more than 10 percent.Ley 1261 de 2008 (approves the Colombia Chile convention), Convention art. 10 (2), art. 11 (2), art. 12 (2), 2008-12-23 official text · verified 2026-10-26

4. Mexico: dividends paid by a company resident in one state to a resident of the other may be taxed only in the state of residence of the recipient, so Colombia levies no dividend tax under the treaty; interest at no more than 5 percent for banks and insurers and 10 percent in other cases, with exemptions for loans by central banks and listed export credit institutions; royalties at no more than 10 percent, and the definition of royalties expressly includes technical assistance, technical services and consulting.
Example: Technical assistance fee of COP 315,843,000 to a Mexican provider: treaty cap 10 percent (COP 31,584,300) instead of 20 percent (COP 63,168,600). / US$100,000 of technical assistance: US$10,000 instead of US$20,000.Ley 1568 de 2012 (approves the Colombia Mexico convention), Convention art. 10 (1), art. 11 (2) and (3), art. 12 (2) and (3), 2012-08-02 official text · verified 2026-10-26

5. United Kingdom: dividends at no more than 0 percent for pension schemes, 5 percent where the beneficial owner is a company holding directly at least 20 percent of the capital, and 15 percent otherwise, but the limits do not apply to dividends out of profits not taxed at Colombian company level; interest at no more than 10 percent, with exemptions for states, pension funds, guaranteed or subsidised loans, credit sales and certain bank loans; royalties at no more than 10 percent.Ley 1939 de 2018 (approves the Colombia United Kingdom convention), Convention art. 10 (2) and (3), art. 11 (2) and (3), art. 12 (2), 2018-10-04 official text · verified 2026-10-26

6. France: dividends at no more than 5 percent where the beneficial owner is a company (other than a partnership) holding directly at least 20 percent of the capital and 15 percent otherwise; interest and royalties at no more than 10 percent. Japan: dividends at no more than 5 percent where the beneficial owner is a company that held at least 20 percent of the voting power for six months including the payment date and 10 percent otherwise; interest at no more than 10 percent; royalties at 2 percent for the use of industrial, commercial or scientific equipment and 10 percent otherwise.Ley 2061 de 2020 (Colombia France convention); Ley 2095 de 2021 (Colombia Japan convention), France and Japan conventions art. 10 (2), art. 11 (2), art. 12 (2), 2021-07-01 official text · verified 2026-10-26

7. Within the Andean Community (Bolivia, Colombia, Ecuador and Peru), Decision 578 allocates taxing rights mainly to the source country: income is taxable only where it has its source; dividends only where the paying company is domiciled; interest only where the payment is charged and recorded; royalties only where the intangible is used; and services, technical assistance and consulting only where the benefit is obtained, presumed to be where the payment is charged and recorded.Comunidad Andina, Decisión 578 de 2004, Art. 3, 9, 10, 11, 14 and 22, 2004-05-04 official text · verified 2026-10-26

8. Income tax on significant economic presence in Colombia applies without prejudice to double taxation conventions, so a provider resident in a treaty country without a permanent establishment in Colombia can rely on the treaty.Estatuto Tributario, added by Ley 2277 de 2022 art. 57, Art. 20-3, par. 4, 2022-12-13 official text · verified 2026-10-26

9. Argentina: Colombia has no income tax convention with Argentina. The only bilateral tax agreement DIAN lists is a convention to avoid double taxation of air and sea navigation companies, in force from 22 March 1971 (Ley 15 de 1970). Payments between the two countries therefore follow each country's domestic rules; for the Argentine side see The Argentine Thread.DIAN list of international tax conventions, Section on conventions for air and sea navigation companies, 1971-03-22 official text · verified 2026-10-26

Country	Dividends	Interest	Royalties	Approving law
Spain	0% (company with 20% or more) / 5%	10% (0% for state, credit sales, bank loans)	10%	Ley 1082 de 2006
Chile	0% (company with 25% or more directly) / 7%	5% (banks, insurers) / 15%	10%	Ley 1261 de 2008
Mexico	Residence state only	5% (banks, insurers) / 10%	10% (includes technical assistance and consulting)	Ley 1568 de 2012
United Kingdom	0% (pension schemes) / 5% (company with 20% or more) / 15%	10%	10%	Ley 1939 de 2018
France	5% (company with 20% or more) / 15%	10%	10%	Ley 2061 de 2020
Japan	5% (20% of votes for six months) / 10%	10%	2% (equipment) / 10%	Ley 2095 de 2021
Andean Community (Bolivia, Ecuador, Peru)	Only where the paying company is domiciled	Only where charged and recorded	Only where the intangible is used	Decisión 578 de 2004
Argentina	No convention: 20%	No convention: 15% or 20%	No convention: 20%	Domestic law

Maximum Colombian withholding under selected conventions, from the texts approved by law (domestic rates: dividends 20 percent, interest 15 or 20 percent, royalties and technical services 20 percent). Conditions and exceptions in each convention apply.

Worked example

US$100,000 (COP 315,843,000) of dividend from a Colombian subsidiary: a Spanish parent with 20 percent or more bears no Colombian withholding, a UK or French parent with 20 percent or more bears US$5,000, a Japanese parent with 20 percent of votes for six months US$5,000, and an Argentine parent US$20,000 under domestic law.
US$100,000 of technical assistance from a Mexican company is a royalty under the Mexico convention and bears at most US$10,000 instead of US$20,000.

Step by step

Identify the recipient's residence and check the DIAN list that the convention is in force for the year of payment.
Confirm the recipient is the beneficial owner and meets the shareholding and holding period conditions of the dividend article.
Obtain evidence of the recipient's tax residence, such as a certificate from its tax authority, before paying, and keep it with the withholding file.
Apply the treaty rate in the monthly withholding return and keep the analysis for the review period of the return.
For Andean Community counterparties, apply Decision 578 source rules instead of a bilateral convention.

Common traps

Brazil, the Netherlands, Luxembourg, Uruguay and the United Arab Emirates conventions are listed by DIAN as not in force; domestic rates apply until they are.
There is no income tax convention with Argentina or the United States; DIAN lists only shipping and air transport agreements with them.
Under the UK convention the reduced dividend rates do not apply to dividends out of profits not taxed at company level in Colombia (art. 10 (3)).
Under the Mexico convention technical assistance and consulting are royalties capped at 10 percent, which differs from the general OECD approach (art. 12 (3)).
Decision 578 gives the source country the right to tax (art. 3), so Colombian tax on payments to Peru, Ecuador or Bolivia is final in Colombia; check how the other country treats that income before structuring through it.

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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