Colombia has issued Decree No. 0898 of 29 July 2026, setting the presumed interest rate for loans between companies and their partners or shareholders at 9.09% for the 2026 tax year and updating inflation-related tax calculations applicable to the 2025 tax year.
Colombia has published Decree No. 0898 of 29 July 2026, establishing the deemed minimum annual interest rate for loans between companies and their partners or shareholders for the 2026 tax year, while also updating the inflationary components used in several tax calculations for the 2025 tax year.
Issued by the Ministry of Finance and Public Credit, the decree amends Decree 1625 of 2016, the Single Regulatory Decree in Tax Matters. It takes effect the day after its publication in the Official Gazette.
Presumed interest rate set for 2026
Under Article 35 of the Tax Statute, monetary loans granted between a company and its partners or shareholders, in either direction, are presumed to generate a minimum annual interest yield proportional to the period the loan remains outstanding.
For the 2026 tax year, the presumed minimum annual interest rate has been set at 9.09%, based on the DTF rate certified by the Banco de la República as at 31 December 2025.
The new rate replaces the 9.25% deemed minimum interest rate that applied for the 2025 tax year.
Inflationary component of financial yields
The decree also establishes the inflationary component of financial yields for the 2025 tax year under Article 40-1 of the Tax Statute.
Using Colombia’s 2025 inflation rate of 5.10%, certified by DANE, and the representative market deposit rate (tasa de captación) of 9.20%, certified by the Superintendencia Financiera, the calculation results in a 55.43% inflationary component.
Accordingly, for individuals and undivided estates (personas naturales y sucesiones ilíquidas) that are not obligated to keep accounting books, 55.43% of financial yields received during 2025 does not constitute income or capital gains for tax purposes.
The same 55.43% proportion also applies to distributions or credits made by mutual investment funds, investment funds and securities funds to these taxpayers.
Financial costs and expenses
For the 2025 tax year, the decree also determines the inflationary component of financial costs and expenses under Article 81-1 of the Tax Statute.
Based on the 2025 inflation rate of 5.10% and the representative market lending rate (tasa de colocación) of 17.99%, the non-deductible portion is calculated at 28.35%.
As a result, 28.35% of interest and financial expenses incurred by individuals and undivided estates not required to keep accounting books cannot be claimed as a tax cost or deduction.
Foreign currency debt treatment
The decree also addresses the tax treatment of foreign currency debt for the 2025 tax year.
It notes that the representative cost of external debt, certified by the Banco de la República, was -5.66% in 2025. Because of this negative rate, exchange rate adjustments (ajustes por diferencia en cambio) and financial costs or expenses relating to foreign currency debts do not constitute a tax cost or deduction for the 2025 tax year.
Effective date
The decree was signed by Germán Ávila Plazas, Minister of Finance and Public Credit, and becomes effective the day after its publication in the Diario Oficial. The decree also confirms that the equivalent percentages applicable to the 2024 tax year and the presumed interest rate for the 2025 tax year remain applicable for prior-year compliance obligations and audits conducted by the DIAN.
