Who is a Large Taxpayer?

Large Taxpayers are legally incorporated legal entities, or their equivalents, and/or individuals, who receive this classification due to their volume of operations, income, assets, importance in collection or for control purposes through a resolution issued by the General Director of the Colombian Tax and Customs Authority (DIAN, for the Spanish original) or their delegate, when they meet at least one of the conditions set forth in Article 1 of Resolution 001253/2022, as amended by Resolution 000191/2024, according to the information available in the DIAN's databases. The classification is determined following a technical study prepared by the Operational Sub-Directorate for Analysis and Strategic Sectors of the Large Taxpayer Operational Directorate, which is subsequently reviewed and approved by the Technical Committee on Control Programs and Campaigns.

Moreover, the General Director of the DIAN may qualify or withdraw the qualification of Large Taxpayer from those proposed by the Large Taxpayer Operational Director at any time, as long as the technical survey indicated in the aforementioned resolution is presented, or those related to the economic activities defined for control by the Programs Committee of the DIAN, in accordance with the provisions of Article 562 of the Tax Code.

What are the requirements to be qualified as a Large Taxpayer?

A taxpayer, filer, responsible party or withholding agent who meets at least one of the following criteria shall be qualified as a Large Taxpayer:

Being in the group of taxpayers who contributed sixty percent (60 %) of the entity's total gross income, at current prices for tax purposes, excluding the value of penalties, during the five (5) years prior to submitting the technical study to the DIAN's Technical Committee on Control Programs and Campaigns.

Legal entities or similar entities that, during the tax year before submitting the technical study to the DIAN's Technical Committee on Control Programs and Campaigns, earned net income - excluding income from occasional earnings - in an amount equal to or greater than five million (5,000,000) Tax Value Units (UVT, for the Spanish original).

Individuals who, during the tax year before submitting the technical report to the DIAN's Technical Committee on Control Programs and Campaigns, reported gross assets equal to or greater than three million (3,000,000) Tax Value Units (UVT).

Individuals and/or legal entities, as well as entities treated as such, that are part of the business group to which the taxpayer who meets the requirement set forth in paragraph 1 belongs, may be classified as Large Taxpayers for control purposes.

In any case, regarding the aforementioned requirements, please refer to Resolution 001253/2022, as amended by Resolution 000191/2024.

Note: Designation as a Large Taxpayer, pursuant to Article 562 of the Tax Code, shall be valid for two (2) calendar years, except in cases where, due to specific circumstances, the relevant administrative act specifies a different period of validity.

What is the process for classifying Large Taxpayers?

The Deputy Director of Operations for Analysis and Strategic Sectors of the Large Taxpayer Operational Directorate, or the person acting in their stead, shall submit the technical study on taxpayers to be classified as Large Taxpayers to the Technical Committee on Control Programs and Campaigns of the National Tax and Customs Directorate (DIAN) Special Administrative Unit.

The technical study shall be prepared according to the criteria set forth in Article 562 of the Tax Code and the criteria established in Articles 1, 2, and 4 of Resolution 001253/2022, as amended by Resolution 000191/2024, and shall include a list and analysis of:

1. Compliance with the requirements by each taxpayer, filer, responsible party, and withholding agent seeking to be classified as a Large Taxpayer.

2. Large Taxpayers that, as of the date the technical qualification study is prepared, do not meet at least one of the requirements and/or criteria set forth in Article 1 of the aforementioned Resolution, or who fall under the circumstances and grounds specified in Articles 2 and 4 thereof.

What are the tax obligations of Large Taxpayers?

1. To file all their returns and payment receipts using the computer services established by the DIAN and within the deadlines established by the national Government using the Electronic Signature Instrument (IFE, for the Spanish original).

2. These taxpayers must pay the total amount of tax due and the estimated income tax in three (3) installments in February, April, and June.

3. The amount of the first installment may not be less than twenty percent (20%) of the balance due for the previous tax year. Once the tax and the income tax prepayment have been calculated on the respective tax return, the amount paid in the first installment will be deducted from the total amount due, and the balance will be paid in two equal installments in April and June.

4. Taxpayers classified as Large Taxpayers for the 2025 and 2026 tax years must, for as long as they retain that classification, file and pay their income and complementary tax returns within the deadlines established by the national government.

5. If they are liable for Sales Tax, their return and payment must be bimonthly and they will have the status of Sales Tax Withholding Agent even if they are not liable for it. This condition must be indicated in the body of the sales invoices.

6. Large Taxpayers must issue electronic invoices.

7. They must submit all the information required by the DIAN on electronic media through the online services, using the pre-validator provided for this purpose and an electronic signature.

What are the grounds for withdrawal of qualification as a Large Taxpayer?

In accordance with the provisions of Resolution 000191/2024, the Director General of the DIAN or their delegate may revoke the designation as a Large Taxpayer based on any of the following grounds at any time, following a technical review submitted by the Large Taxpayer Operational Director or the person acting in their stead to the Technical Committee on Control Programs and Campaigns:

1. Being subject to any of the types of liquidation proceedings provided under Colombian law.

2. Having been declared a fictitious supplier.

3. The qualified individual being registered in the RUT as an undistributed estate.

4. When proceedings have been initiated to forfeit the assets of the Large Taxpayer or any of the companies that are part of the same business group, whether as a subsidiary or a parent company.

5. When, notwithstanding the provisions of paragraph 4 of Article 1 of the aforementioned resolution, a taxpayer, filer, responsible party, or withholding agent classified as a Large Taxpayer is absorbed or dissolved as part of a merger or spin-off, respectively.

Who cannot be qualified as Large Taxpayers?

The following taxpayers, filers, responsible parties, or withholding agents shall not be classified as Large Taxpayers, even if they meet the criteria set forth in Article 1 of Resolution 001253/2022, as amended by Resolution 000191/2024:

1. Individuals whose primary economic activity is listed in the Single Tax Registry (RUT, for the Spanish original), such as:

 1. Salaried employee, code 0010

 2. Retired, code 0020

 3. Capital investors, code 0090

 4. Dependents of third parties, code 0081

 5. No economic activity, code 0082, who only meet the criterion established in clause 3 of Article 1 of Resolution 001253/2022, as amended by Resolution 000191/2024.

2. Foreign companies not domiciled in Colombia, which have registered code 08 "Foreign company without domicile, but with investment in Colombia" in box 67 - FOREIGN COMPANIES AND ORGANIZATIONS of the Single Tax Registry.

3. Being subject to the grounds for withdrawal of the qualification as Large Taxpayer.

In any case, the provisions of paragraph 3 of Article 1 of Resolution 001253/2022, as amended by Resolution 000191/2024, must be taken into account.

Large Taxpayers, 2025-2026 term

Resolution 000200 of December 27, 2024: "By means of which some taxpayers, responsible parties and/or withholding agents are qualified as large taxpayers"

Frequently Asked Questions

Who can be qualified as a Large Taxpayer?

Those who meet at least one of the conditions specified in Article 1 of Resolution 001253/2022, as amended by Resolution 000191/2024, and who are not involved in events in which qualification as a Large Taxpayer is not granted, may be classified as Large Taxpayers. Furthermore, taxpayers engaged in economic activities defined by the DIAN's Technical Program Committee for control purposes may also be classified as Large Taxpayers.　

Who must update their RUT by registering their responsibility as Large Taxpayers?

Each regional office automatically updates the RUT, including responsibility 13 "Large Taxpayer," once the resolution granting the designation is published.　

As of when can the status of Large Taxpayer and VAT Withholding Agent be announced?

When responsibility 13 is registered in the RUT. 　

Can the taxpayer request the qualification as Large Taxpayer to be removed?

The status of Large Taxpayer is removed at the discretion of the General Director of the DIAN when the taxpayer is involved in any of the grounds provided in Resolution 001253/2022, modified by Resolution 000191/2024.

Can a taxpayer request to be granted qualification as a Large Taxpayer?

The status of Large Taxpayer can only be granted as a result of the technical survey ordered by Resolution 001253/2022, modified by Resolution 000191/2024, after verification and analysis by the Technical Committee for Control Programs and Campaigns of the DIAN.

Glossary

TO QUALIFY. The act of authorizing, accrediting or granting a quality to a person or entity. Source: UAE Colombian Tax and Customs Authority  (DIAN) Operational Sub-directorate of Analysis and Strategic Sectors.

TO WITHDRAW QUALIFICATION. The act of overruling or annulling the authorization or qualification previously granted to a person or entity. Source: UAE Colombian Tax and Customs Authority (DIAN) Operational Sub-directorate of Analysis and Strategic Sectors.

EAR. Authorized collection entities (Banks). Source: DIAN Resolution 478/2000

LARGE TAXPAYER. Legally incorporated legal entities, or their equivalents, or individuals who must have this qualification due to their volume of operations, income, assets, importance in collection and economic activity. Source: Article 562 of the Tax Code.

RUT The Single Tax Registry is the sole mechanism for identifying, locating, and classifying individuals and entities that qualify as income taxpayers and non-taxpayers filing income and equity; those subject to the General Tax Regime and those under the simplified regime (currently taxpayers and non-taxpayers); withholding agents; importers, exporters, and other customs users, and all other parties subject to obligations administered by the Colombian Tax and Customs Authority, for whom the Directorate requires registration. Source: Article 555-2 of the Tax Code.

UVT. According to Article 868 of the Tax Code, the Tax Value Unit (UVT) was created to unify and facilitate compliance with tax obligations. The UVT is the unit of value that allows adjusting amounts in provisions relating to taxes and obligations administered by the Colombian Tax and Customs Authority. The amount of the tax value unit shall be adjusted annually based on the variation in the consumer price index for middle income, certified by the National Administrative Department of Statistics, for the period between October 1 of the year prior to the tax year and the same date of the year immediately preceding it. Source: Article 868 of the Tax Code.