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Free trade zones in Colombia: user types, the 20 percent export based income tax rate, investment and job commitments, and how goods move in and out

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

A Colombian free trade zone (zona franca) is a delimited area whose goods are treated as outside the national customs territory for import and export taxes; foreign goods enter without duty or VAT and pay them only when they are sold into Colombia. Industrial users pay 20 percent income tax on the export share of their income and the general 35 percent on the rest, provided they sign a yearly internationalization and sales plan with the Ministry of Commerce, while commercial users pay the general rate. New single company zones and new users must commit to investment and direct jobs measured in UVT, and the operator posts a 100,000 UVT customs guarantee.

USD figures use the TRM (tasa representativa del mercado) 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 the national open data portal. Amounts in UVT 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 zone industrial users on export income20 %Estatuto Tributario art. 240-1 num. 1, as of 2026-10-26 · in force
Income tax rate for free zone industrial users on non export income35 %Estatuto Tributario art. 240-1 num. 2 and art. 240, as of 2026-10-26 · in force
Maximum term of a free zone declaration, extendable once30 yearsDecreto 2147 de 2016 art. 23, as of 2026-10-26 · in force
Minimum new investment for a multi user permanent free zone924224 UVTDecreto 2147 de 2016 art. 29 num. 1, as of 2026-10-26 · in force
Minimum industrial users of a permanent free zone by year five5 usersDecreto 2147 de 2016 art. 29 num. 1, as of 2026-10-26 · in force
Minimum new investment for a single company special free zone for goods3012550 UVTDecreto 2147 de 2016 art. 32, as of 2026-10-26 · in force
Direct jobs required for a single company special free zone for goods150 jobsDecreto 2147 de 2016 art. 32, as of 2026-10-26 · in force
Customs guarantee of a free zone operator100000 UVTDecreto 1165 de 2019 art. 476, as of 2026-10-26 · in force

The rule

1. A free trade zone is a delimited area of the national territory where industrial activities in goods and services, or commercial activities, are carried out under special tax, customs and foreign trade rules; goods brought into it are considered outside the national customs territory for import and export taxes. There are four kinds of users: the operator, which runs and promotes the zone and qualifies its users; industrial users of goods, which produce, transform or assemble goods; industrial users of services (logistics, IT and data, research, health, tourism, repairs, technical support, auditing and consulting, among others); and commercial users, which market, sell or store goods. Industrial users must be installed exclusively inside the zone.
Cost to do it: Becoming a user requires a new company (or a branch of a foreign company with no prior activity in Colombia) domiciled in the zone, plus the operator's own fees, which are private and negotiated.
Example: A Medellín logistics company that wants free zone status sets up a new SAS domiciled inside a permanent free zone and applies to the operator for qualification as an industrial user of services. / A US manufacturer can hold a free zone user through a Colombian SAS or a registered branch, as long as the entity has not operated before in Colombia (Decreto 2147 de 2016 art. 80 num. 1).Ley 1004 de 2005 (free trade zone regime), Art. 1 and art. 3, 2005-12-30 official text · verified 2026-10-26
2. Industrial users of free trade zones apply a 20 percent income tax rate to the share of taxable income that corresponds to revenue from exports of goods and services, and the general rate (35 percent) to the rest; commercial users pay the general rate. Operators, offshore free zones, port services zones, refineries and logistics users pay a flat 20 percent. To use the 20 percent rate an industrial user must agree a yearly internationalization and annual sales plan with the Ministerio de Comercio, Industria y Turismo setting maximum income from sales into the national customs territory; without it, or if the targets are missed, the whole income is taxed at the general rate. The Constitutional Court upheld the rule but held that the previous flat 20 percent regime (Ley 1819 de 2016 art. 101) keeps applying to taxpayers that met its conditions before 13 December 2022.
Cost to do it: No filing fee for the plan, but its yearly compliance must be tracked; missing the plan costs the gap between 20 and 35 percent on the export share of income.
Example: An industrial user with COP 3,158,430,000 of taxable income and 60 percent of its revenue from exports pays 20 percent on 60 percent and 35 percent on 40 percent: COP 821,191,800, against COP 1,105,450,500 at the general rate. / On US$1,000,000 of taxable income with a 60 percent export share the tax is US$260,000 instead of US$350,000, a saving of US$90,000 a year.Estatuto Tributario art. 240-1 as amended by Ley 2277 de 2022 art. 11; Corte Constitucional Sentencia C-384 de 2023, Art. 240-1 num. 1 to 3, par. 1, 5 and 6; C-384 de 2023 resolutive point two, 2022-12-13 official text · verified 2026-10-26 · changed: Ley 2277 de 2022, in force 13 December 2022, replaced the flat 20 percent rate for industrial users with the export based split from tax year 2024 (20 percent flat for 2023). Sentencia C-384 de 2023 kept the old regime for users that met its conditions before 13 December 2022.
3. The Ministerio de Comercio, Industria y Turismo declares a free trade zone after approving its master development plan and receiving a favourable opinion of the Intersectoral Free Zones Commission. A declaration lasts up to 30 years and may be extended for another 30. A multi user permanent free zone must show at least five industrial users within five years and new investment by them or the operator of at least 924,224 UVT (reduced by 10 to 30 percent in municipalities with high multidimensional poverty), and its operator must hold equity of 567,008 UVT. A single company special zone for goods must make new investment of at least 3,012,550 UVT and create 150 direct jobs within three years; special zones for services need 209,004 UVT and 500 jobs, more than 961,449 UVT and 350 jobs, or more than 1,922,898 UVT and 150 jobs. At least 90 percent of the committed jobs must be kept from the second year after start up.
Cost to do it: 924,224 UVT is COP 48,405,307,776 (about US$15.3 million); 3,012,550 UVT is COP 157,779,293,700 (about US$50.0 million); 209,004 UVT is COP 10,946,375,496 (about US$3.5 million).
Example: A single company special zone for goods, such as a new plant, must invest at least COP 157,779,293,700 and hire 150 direct workers within three years of the declaration. / A services company planning a US$4 million campus needs more than 209,004 UVT (about US$3.5 million) of new investment and 500 direct formal jobs to qualify as a special zone for services.Decreto 2147 de 2016 (free trade zone regulation, Ministerio de Comercio, Industria y Turismo) as amended by Decreto 278 de 2021, Art. 19, art. 23, art. 29 num. 1 and 2, art. 32 and art. 33, 2021-03-15 official text · verified 2026-10-26
4. A company qualifying as an industrial or commercial user in an existing permanent free zone commits investment and jobs according to its productive real fixed assets: below 12,326 UVT no new investment is required but it must create 3 direct jobs at start up and 2 more in each of the next two years (7 in total); from 12,327 to 123,263 UVT, new investment of 20,092 UVT within three years and 20 jobs; from 123,264 to 739,576 UVT, 100,459 UVT and 30 jobs; above 739,577 UVT, 231,068 UVT and 50 jobs. The applicant must be a new legal entity, or a branch of a foreign company with no prior activity in Colombia, domiciled in the zone, with no enforceable debts to DIAN.
Cost to do it: 20,092 UVT is COP 1,052,298,408 (about US$333,171); 100,459 UVT is COP 5,261,439,666 (about US$1.67 million); 231,068 UVT is COP 12,101,955,432 (about US$3.83 million).
Example: A software services start up with COP 300,000,000 of fixed assets, below 12,326 UVT (COP 645,561,924), needs no new investment but must reach 7 direct formal jobs by its third year. / A firm bringing US$5 million of fixed assets (about 301,500 UVT) must add 100,459 UVT, about US$1.67 million, of new investment within three years and 30 direct jobs.Decreto 2147 de 2016 as amended by Decreto 278 de 2021, Art. 80 num. 1, 6 and 12 to 15, 2021-03-15 official text · verified 2026-10-26
5. Goods from abroad brought into a free trade zone by its users are not an import: they only need to be consigned to a user in the transport document. Sales and shipments from the zone abroad are exports. Raw materials, parts and finished goods sent from the rest of Colombia to an industrial user are a definitive export, and are VAT exempt with a right to refund when needed for the user's corporate purpose. Goods moved from the zone into the rest of Colombia are an import: duties are charged on customs value minus the national value added and nationalized inputs, at the rate of the final product, and VAT is charged on the usual base. The operator authorizes every entry and exit.
Cost to do it: Duty and VAT are deferred until goods leave for the national market; exports from the zone pay neither.
Example: Machinery worth COP 315,843,000 imported into the zone pays no duty or VAT; if it is later sold to a Bogotá buyer, the import declaration is filed then. / A product made in the zone from US$40,000 of foreign parts and US$60,000 of Colombian value added pays duty only on the US$40,000 foreign component when sold into Colombia (art. 483 and 485).Decreto 1165 de 2019 (customs regime); Estatuto Tributario art. 481 lit. e, Decreto 1165 art. 475, art. 477, art. 478, art. 479, art. 482, art. 483 and art. 485, 2019-07-02 official text · verified 2026-10-26
6. Within one month of the decree declaring a zone, its operator must give DIAN a global guarantee of 100,000 UVT to secure customs duties, fines and interest arising from its obligations; without it the declaration lapses. The administrator of a temporary free zone for fairs and events posts a specific guarantee of 5,000 UVT. The operator may let goods leave temporarily for partial processing or tests outside the zone for up to 6 months (extendable by 3), and capital goods for repair for up to 3 months (extendable once).
Cost to do it: 100,000 UVT is COP 5,237,400,000 (about US$1.66 million); 5,000 UVT is COP 261,870,000 (about US$82,911). The premium on an insurance or bank guarantee is a private cost.
Example: An operator that runs two zones may post one global guarantee of 200,000 UVT, COP 10,474,800,000. / An event organizer running a temporary free zone for a trade fair posts a guarantee of about US$82,911 unless only advertising or academic material is involved.Decreto 1165 de 2019, Art. 476, art. 489 and art. 490, 2019-07-02 official text · verified 2026-10-26
Productive real fixed assetsNew investment within 3 yearsCOPUSD (approx.)Direct formal jobs
Below 12,326 UVTNone007 (3 at start up, 2 in year two, 2 in year three)
12,327 to 123,263 UVT20,092 UVT1,052,298,408333,17120
123,264 to 739,576 UVT100,459 UVT5,261,439,6661,665,84030
Above 739,577 UVT231,068 UVT12,101,955,4323,831,63650

Investment and job commitments for a new user qualifying in an existing permanent free zone (Decreto 2147 de 2016 art. 80 num. 12 to 15), at the 2026 UVT of COP 52,374 and COP 3,158.43 per US dollar.

ItemRateCOPUSD
Export share (60%)20%379,011,600120,000
Non export share (40%)35%442,180,200140,000
Total with an agreed internationalization plan26% effective821,191,800260,000
Total without the plan or missing its targets35%1,105,450,500350,000

Income tax of a free zone industrial user with COP 3,158,430,000 (US$1,000,000) of taxable income and 60 percent export revenue (Estatuto Tributario art. 240-1).

Worked example

  • A European food processor plans a plant to supply the Andean region and qualifies a new Colombian SAS as an industrial user of goods in an existing permanent free zone. Its fixed assets of US$5 million fall in the 123,264 to 739,576 UVT band, so it commits 100,459 UVT (about US$1.67 million) of new investment within three years and 30 direct jobs (Decreto 2147 de 2016 art. 80).
  • Its imported machinery and raw materials enter the zone without duty or VAT (Decreto 1165 de 2019 art. 477). Packaging bought from Colombian suppliers is VAT exempt because it is needed for its corporate purpose (Estatuto Tributario art. 481 lit. e).
  • In its first full year it earns COP 3,158,430,000 (US$1,000,000) of taxable income, 60 percent from exports. With its internationalization plan signed with the Ministry of Commerce it pays COP 821,191,800 (US$260,000) of income tax instead of COP 1,105,450,500 (US$350,000) (art. 240-1).
  • When it sells a lot to a Colombian supermarket chain, the buyer or the user files an import declaration and pays duty only on the foreign inputs, plus VAT (Decreto 1165 de 2019 art. 483 and 485).

Step by step

  1. 1. Decide between joining an existing permanent free zone (faster, the operator qualifies you) or applying for a single company special zone (higher investment and job thresholds, MinCIT declaration).
  2. 2. Incorporate a new company or register a branch of a foreign company with no prior activity in Colombia and domicile it in the zone (Decreto 2147 de 2016 art. 80 num. 1).
  3. 3. Prepare the project description, financial structure, investment and job schedule and environmental compliance, and file with the operator (art. 80 num. 7 to 16).
  4. 4. Once qualified, sign the internationalization and annual sales plan with MinCIT each tax year to use the 20 percent rate on export income (Estatuto Tributario art. 240-1 par. 6).
  5. 5. Move goods only with the operator's authorization forms in DIAN's electronic services; file import declarations when goods go to the national market (Decreto 1165 de 2019 art. 475 and 482).
  6. 6. Track investment and jobs against the schedule each year; keep at least 90 percent of committed jobs from the second year after start up.

Common traps

  • Assuming the 20 percent rate is automatic. Since 2024 it applies only to the export share of income and only with a yearly plan agreed with MinCIT; otherwise the general 35 percent rate applies (Estatuto Tributario art. 240-1 par. 6).
  • Qualifying an existing operating company. Users must be new entities or branches with no prior activity in Colombia (Decreto 2147 de 2016 art. 80 num. 1).
  • Missing job or investment commitments. Failure to meet them, or to keep 90 percent of committed jobs, is a ground to lose the declaration or qualification (Decreto 2147 de 2016 art. 32 and art. 33).
  • Forgetting the minimum tax. Free zone users are also subject to the 15 percent minimum effective tax (Tasa de Tributación Depurada) of Estatuto Tributario art. 240 par. 6, which expressly covers art. 240-1 taxpayers.
  • Treating domestic sales from the zone as tax free. Goods sold into Colombia are imports and pay duty on the foreign component plus VAT (Decreto 1165 de 2019 art. 482 and 483).
  • Commercial users expecting the reduced rate. They pay the general rate (Estatuto Tributario art. 240-1 par. 1).

Sources

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