DIAN details Tidis use for $25B tax refunds after court strikes down emergency decree

Following the Constitutional Court's ruling on Legislative Decree 1474/2025, Colombia's DIAN will process $25 billion in refunds using Tax Refund Titles (Tidis) for amounts over 1,000 UVT, with cash for smaller claims. Tidis are tradable debt instruments usable only for DIAN taxes.

The Constitutional Court ordered refunds of funds collected under the unconstitutional decree, including $23.8 billion from a 1% tax on first exports of coal and hydrocarbons, and $1.2 billion from additional VAT on liquor imports. DIAN must implement mechanisms within 30 days.

For refunds exceeding 1,000 UVT (roughly $45,000), DIAN will issue Tidis—debt titles from the Nation via the Ministry of Finance. These are delivered through refund resolutions and deposited into taxpayers' subaccounts at authorized banks like Bancolombia. As national currency instruments, Tidis can only offset taxes managed by DIAN and must be redeemed in the following calendar year or depreciate.

Former DIAN director Lisandro Junco described them as 'bonds that the State delivers when it has to return taxes to someone.' Taxpayers can trade Tidis on the market for liquidity by selling to parties with DIAN tax obligations.

DIAN will issue mass resolutions after cross-checking data and verifying payments, particularly for indirect taxes like VAT or consumption levies. Taxpayers must prove payments to claim refunds, which vary by amount: cash for small claims (e.g., a bottle of liquor) or Tidis for larger ones.

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Symbolic illustration of Colombia's Constitutional Court ordering $25B tax refund, with money flowing to governors amid ruling.
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Constitutional Court orders return of $25 billion collected during emergency

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Colombia's Constitutional Court declared Legislative Decree 1474 of 2025 unconstitutional and ordered the Dian to return about $25 billion collected from emergency economic taxes in December. The Dian confirmed it will comply and implement measures within 30 days. Governors welcomed the ruling for easing regional finances.

After the Constitutional Court struck down the December 2025 emergency economic decree, the Colombian government will present a tax reform to raise $16 trillion. Finance Minister Germán Ávila and President Gustavo Petro confirmed the plan in response to the fiscal imbalance. The measure aims to avoid cuts to social spending and address inherited deficits.

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The Colombian government issued several decrees under the Economic, Social and Ecological Emergency declared due to floods in eight departments, including a 16% tax on digital bets and an $8.6 trillion addition to the 2026 budget. These measures aim to fund aid for victims and revive the local economy. Critics like Andi and AmCham question their impact on investment.

The Colombian Chamber of Infrastructure (CCI) responded to President Gustavo Petro's statements suggesting that the fiscal deficit could be offset by cuts to investments in already contracted road concessions and the return of resources held in trusts. The business group clarified that those funds are not available surpluses but resources earmarked for ongoing works, and the actual available amount is $6.5 trillion, not $18 trillion as claimed by the president.

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Building on this week's announcement of a phased corporate tax cut from 27% to 23%, Chile's Finance Ministry detailed a reactivation bill under President José Antonio Kast that reintegrates the progressive tax system and allows withdrawals from accumulated Tax Utility Fund (FUT) balances to spur investment. The package targets 200,000 new jobs and 4% growth.

The Banco de la República reported record profits of $13.9 trillion for the end of 2025, mainly driven by net income from international reserves. These earnings surpass Ecopetrol's transfers for the second consecutive year. The bank will transfer $13.8 trillion to the National Government, partly in debt securities and partly in cash.

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