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Withholding tax on dividends, interest, royalties, services and other payments from Colombia to non residents

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

Money paid by a Colombian company to a non resident is taxed at source: 20 percent on dividends out of taxed profits (48 percent combined out of untaxed profits), 20 percent on royalties, services and technical assistance, 15 percent on interest on loans of a year or more and 33 percent on management fees. Payments to low tax jurisdictions bear 35 percent, branch remittances count as dividends, and foreign portfolio investors pay 14 percent or 5 percent through their local administrator. A government bill in committee would raise dividend withholding to 30 percent.

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

Withholding on dividends to foreign companies and non resident individuals, out of taxed profits	20 %Estatuto Tributario art. 245 (Ley 2277 de 2022 art. 4), as of 2026-10-26 · in force
Combined tax on dividends to non residents out of untaxed profits (35% then 20% on the remainder)	48 %Estatuto Tributario art. 245 par. 1, as of 2026-10-26 · in force
Withholding on royalties paid to non residents	20 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on services, consulting and technical assistance paid to non residents	20 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on interest on foreign loans of one year or more	15 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on other interest paid to non residents	20 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on management or direction fees paid to non residents	33 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on taxable payments to non cooperative, low or no tax jurisdictions or preferential regimes	35 %Estatuto Tributario art. 408 par. and art. 240, as of 2026-10-26 · in force
Withholding on interest on loans of eight years or more for public private partnership infrastructure	5 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on leasing of ships, helicopters and aircraft from foreign lessors	1 %Estatuto Tributario art. 408, as of 2026-10-26 · in force
Withholding on international air and sea transport by foreign carriers	5 %Estatuto Tributario art. 414-1, as of 2026-10-26 · in force
Withholding on other payments to non residents not listed elsewhere	15 %Estatuto Tributario art. 415, as of 2026-10-26 · in force
Withholding on monthly profit of foreign portfolio investors (non tax haven)	14 %Estatuto Tributario art. 18-1 num. 4 lit. e, as of 2026-10-26 · in force
Withholding on foreign portfolio investors' profit on fixed income securities	5 %Estatuto Tributario art. 18-1 num. 4 lit. f, as of 2026-10-26 · in force
Withholding on dividends to foreign shareholders proposed in bill 004 de 2026 Cámara (in committee)	30 %Proyecto de Ley 004 de 2026 Cámara art. 14, as of 2026-10-26 · pending
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. Anyone making payments or credits of income taxable in Colombia to foreign companies or entities without domicile in Colombia, to foreign individuals without residence, or to estates of non resident foreigners must withhold income tax.
Cost to do it: No fee; the Colombian payer files a monthly withholding return and issues the withholding certificate.Estatuto Tributario (Decreto 624 de 1989), Art. 406, 1989-03-30 official text · verified 2026-10-26

2. Dividends paid to foreign companies without their main domicile in Colombia, to non resident individuals and to estates of non residents bear 20 percent income tax, withheld at source on the gross payment. Where the dividend comes from profits that were not taxed at company level under the art. 48 and 49 calculation, the company rate of art. 240 (35 percent) applies first and the 20 percent applies to what remains.
Example: Dividend of COP 100,000,000 out of taxed profits: COP 20,000,000 withheld. Out of untaxed profits: COP 35,000,000 plus 20 percent of COP 65,000,000 (COP 13,000,000) = COP 48,000,000. / About US$31,661 of dividend: about US$6,332 withheld from taxed profits, about US$15,197 from untaxed profits.Estatuto Tributario, as amended by Ley 2010 de 2019 art. 51 and Ley 2277 de 2022 art. 4, Art. 245, first paragraph, par. 1 and par. 2, 2022-12-13 official text · verified 2026-10-26

3. The company computes each year the maximum profit it can distribute as non taxed: taxable income plus taxable occasional gains, minus basic income tax and occasional gains tax (net of foreign dividend tax credits), plus non taxed dividends received from Colombian and Andean Community companies. Commercial profit above that figure is taxed in the hands of shareholders when distributed. An excess of taxed profit over commercial profit may be carried to the following five years or back to the two prior years, and the company must tell shareholders, at distribution, how much is non taxed.Estatuto Tributario, as amended by Ley 1607 de 2012 art. 92, Art. 49, num. 1 to 7 and par. 2, 2012-12-26 official text · verified 2026-10-26

4. A distribution of profits includes any transfer of profits charged to equity, in cash or in kind, other than capital reductions and share premium, and also the transfer to a related company abroad of profits from Colombian source income earned through a branch or permanent establishment, so branch remittances are taxed like dividends.Estatuto Tributario, as amended by Ley 1819 de 2016 art. 30, Art. 30, num. 1 and 2, 2016-12-29 official text · verified 2026-10-26

5. Withholding on other payments to non residents, on the nominal amount: 20 percent on interest, commissions, fees, royalties, rents, personal services, industrial property and know how, other services, literary, artistic and scientific property, films and software; a single 20 percent on consulting, technical services and technical assistance whether rendered in Colombia or from abroad; 15 percent on interest on foreign loans of one year or more and on the financial component of cross border leasing; 1 percent on leasing of ships, helicopters and aircraft and on reinsurance premiums; 5 percent on interest on loans of eight years or more for public private partnership infrastructure under Ley 1508 de 2012; 33 percent on management or direction fees; 10 percent on sales or services by non residents with significant economic presence not covered elsewhere.
Example: Technical assistance fee of COP 200,000,000: COP 40,000,000 withheld. Management fee of the same amount: COP 66,000,000. / About US$63,323 of fees: about US$12,665 withheld for technical assistance, about US$20,896 for management fees.Estatuto Tributario, as amended by Ley 2010 de 2019 art. 98 and Ley 2277 de 2022 art. 61, Art. 408, first to eighth paragraphs, 2022-12-13 official text · verified 2026-10-26

6. Any taxable payment to a resident of a jurisdiction classified by the Colombian government as non cooperative or of low or no taxation, or to an entity under a preferential tax regime, bears withholding at the general corporate rate (35 percent).Estatuto Tributario, as amended by Ley 2010 de 2019 art. 98, Art. 408, paragraph, 2019-12-27 official text · verified 2026-10-26

7. International air and sea transport services rendered by carriers without domicile in Colombia bear 5 percent withholding, and such carriers need not file a return. Payments to non residents for items not listed elsewhere bear 15 percent, and occasional gains 10 percent of the gross amount.Estatuto Tributario, art. 414-1 and art. 415 as amended by Ley 1819 de 2016 art. 128 and 129; art. 592 num. 4, Art. 414-1; art. 415; art. 592 num. 4, 2016-12-29 official text · verified 2026-10-26

8. Foreign portfolio investors pay income tax only through monthly withholding by their local administrator on monthly net profit: 14 percent in general, 25 percent if the investor is domiciled in a jurisdiction classified as a tax haven, and 5 percent on public or private fixed income securities and derivatives on them. Dividends are withheld by the paying company at the art. 245 rate. These withholdings are the final tax and the investor need not file, and the regime does not apply where a Colombian resident controls the investment.Estatuto Tributario, as amended by Ley 1607 de 2012 art. 125 and Ley 2010 de 2019 art. 82, Art. 18-1, num. 2, 3, 4 lit. e and f, num. 5 and par. 4, 2019-12-27 official text · verified 2026-10-26

9. Foreign companies and individuals without residence or domicile in Colombia need not file an income tax return if all their income was subject to the withholding of art. 407 to 411 and that withholding was actually applied.Estatuto Tributario, Art. 592, num. 2, 1989-03-30 official text · verified 2026-10-26

10. Payments to a foreign parent or head office for administration or direction and for intangibles are deductible for the Colombian subsidiary or branch only if income tax was withheld; payments abroad for other items follow the general foreign expense rules of art. 121 and 122.Estatuto Tributario, as amended by Ley 223 de 1995 art. 85 and Ley 1819 de 2016 art. 73, Art. 124 and its paragraph, 1995-12-20 official text · verified 2026-10-26

11. Pending: bill 004 de 2026 Cámara, filed by the government on 20 July 2026 and in committee in the Third Committee of the Chamber when this page was checked, would raise the dividend withholding for foreign shareholders and non residents in art. 245 from 20 to 30 percent, and to 30 percent for dividends paid to permanent establishments under art. 246. It is not law.Proyecto de Ley 004 de 2026 Cámara, Art. 14 and art. 15 of the bill, 2026-07-20 official text · verified 2026-10-26

Payment	Rate	Withheld (COP)	Withheld (USD)	Net to recipient (USD)	Norm
Dividend out of taxed profits	20%	63,168,600	US$20,000	US$80,000	Art. 245
Dividend out of untaxed profits	48%	151,604,640	US$48,000	US$52,000	Art. 245 par. 1
Royalty or software licence	20%	63,168,600	US$20,000	US$80,000	Art. 408
Technical assistance or consulting from abroad	20%	63,168,600	US$20,000	US$80,000	Art. 408
Interest, loan of one year or more	15%	47,376,450	US$15,000	US$85,000	Art. 408
Interest, loan under one year	20%	63,168,600	US$20,000	US$80,000	Art. 408
Management or direction fee	33%	104,228,190	US$33,000	US$67,000	Art. 408
Any taxable payment to a low tax jurisdiction	35%	110,545,050	US$35,000	US$65,000	Art. 408 par.
International air or sea freight	5%	15,792,150	US$5,000	US$95,000	Art. 414-1

US$100,000 paid by a Colombian company to a non resident with no treaty, at the TRM of COP 3,158.43 (COP 315,843,000). Treaties may lower these rates (see taxes/tax-treaties).

Worked example

Dividend out: a Colombian SAS with COP 1,000,000,000 (about US$316,613) of taxable profit pays COP 350,000,000 of income tax; on paying the remaining COP 650,000,000 to its foreign parent it withholds COP 130,000,000, so the parent receives COP 520,000,000 (about US$164,639): a combined 48 percent before treaty relief.
Branch profits: a branch that remits COP 500,000,000 of after tax Colombian source profit to its head office is treated as paying a dividend (art. 30 num. 2) and withholds 20 percent, COP 100,000,000 (about US$31,661).
Royalty versus management fee: the same COP 315,843,000 (US$100,000) bears US$20,000 of withholding as a royalty but US$33,000 as a management fee, and a management fee is deductible only if the withholding was applied (art. 124).

Step by step

Classify every payment abroad before paying: dividend, royalty, technical service, interest (and loan term), management fee or other, because each has its own rate in art. 245, 408, 414-1 or 415.
Check whether the recipient is in a jurisdiction classified as non cooperative or low tax, or under a preferential regime: if so the rate rises to 35 percent (art. 408 par.).
Check whether a treaty applies and keep the documents that support the reduced rate (see taxes/tax-treaties).
Withhold on payment or on crediting the account, whichever is first, and declare and pay in the monthly withholding return on the calendar of Decreto 1625 de 2016.
For dividends, use the art. 49 calculation to split taxed and untaxed profits before applying the 20 percent or the 35 plus 20 percent.
Channel the net payment through the FX market (see fx/fx-and-capital-controls) and keep the withholding certificate with the FX declaration.

Common traps

Technical services rendered entirely from abroad are still Colombian source and bear 20 percent withholding (art. 24 num. 8; art. 408).
Interest on a loan under one year bears 20 percent, not 15 percent (art. 408).
Dividends out of profits that were not taxed at company level bear 35 percent before the 20 percent, a combined 48 percent (art. 245 par. 1).
Management fees bear 33 percent and are deductible only if the withholding was applied (art. 124 and 408).
Branch profit remittances are dividends for tax purposes (art. 30 num. 2), so branches do not avoid the dividend withholding.
The 2026 reform bill would lift dividend withholding to 30 percent; it was in committee on 26 October 2026 (see taxes/tax-system-overview).

Sources

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