Colombia · Tax regime
Colombian Tax Residency and Wealth Tax
Ley 2277 of 2022 made the impuesto al patrimonio permanent. We read art. 292-3 verbatim: it contains no exclusion for foreign residents.
We include this as a programme because it is the decisive fact about Colombia and it is systematically hidden. Colombia is the only major destination in this region that levies an annual wealth tax on a new resident's worldwide assets with no exemption, no holiday and no phase-in. For an eight-figure family the wealth tax alone can exceed the entire cost of a Panamanian or Paraguayan alternative every single year.
Qualifying routes
72,000 UVT × 52,374 = COP 3,770,928,000 ≈ USD 1.16M of net assets (art. 294-3); the first 12,000 UVT of a primary residence is excluded
The facts
- Qualifying figure
- 3770.9M COP
- Total landed cost
- 0.5% to 1.5% of worldwide net assets annually for residents above the threshold
- Physical presence
- 183 days, continuous or discontinuous, in any 365-day window; if the window straddles two years, residency begins in the second year (art. 10 ET)
- Family
- individual
- Permanent residency
- not applicable
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Permitted
- Requirements
- 183 days in any 365-day window triggers residencyannual DIAN filing of worldwide income and assetswealth tax return where net assets exceed 72,000 UVT
- The 5-year exclusion for foreign residents' foreign assets under the old Ley 1943/2010 did NOT survive into Ley 2277 art. 292-3. A foreign tax resident is exposed on worldwide net assets from day one. This is high-confidence, read verbatim from the statute, and it contradicts a great deal of published advice.
- Rates are 0.5% / 1.0% / 1.5%. The 1.5% band is temporary for 2023–2026 under art. 296-3's parágrafo; from 2027 the top rate falls to 1.0% above 122,000 UVT.
- Non-residents are taxed on Colombian-situs assets only — which is precisely why the planning answer is usually to hold the visa and stay under 183 days.
- 2025–26 demonstrated the political risk vividly: the Ley de Financiamiento was archived 9 December 2025; the government declared an economic emergency; Decreto 1474/2025 cut the threshold to 40,000 UVT with rates to 5%; the Constitutional Court struck it down in Sentencia C-079/2026 (following C-075/2026 voiding enabling Decreto 1390), retroactively with DIAN refunds. A second emergency decree (150/2026, floods) was conditionally upheld but its wealth tax expressly excludes natural persons, reaching only legal persons above 200,000 UVT at 0.5%/1.6%.
- Colombia has CFC (ECE) rules under arts. 882+ ET, signed the CRS MCAA on 29 October 2014 with first exchange in 2017, and joined the OECD in 2020. There is no opacity here.
- There is no expatriation exit tax, but the impuesto de timbre por salida del país (Decreto 0625 of 19 June 2026) is a per-trip departure levy. The two are frequently and wrongly conflated.