Per diems vs reimbursement in Colombia: what matters to the DIAN
Colombian employers conflate per diems with reimbursement. The DIAN treats them very differently — and so should you.
The two DIAN categories
Per diems (viáticos) under CST Art.[^cst-art130] 130: a fixed amount the employer pays the worker to cover trip expenses. Either permanent (part of salary) or accidental (for one specific trip).
Expense reimbursement: payment against real receipts of expenses the worker incurred (fuel, tolls, hotels, meals), with an electronic invoice or 'documento soporte por no obligados a facturar'.
The distinction looks subtle but draws the line between 'forms part of salary' and 'does not' — which changes parafiscal contributions, severance accruals, withholding, and deductibility.
Permanent per diems
A permanent per diem is paid regularly for routine duties (typical for sales reps and field engineers). Both the labor code and Supreme Court case law treat it as salary: it folds into the IBC base for parafiscals (SENA, ICBF, cajas), social benefits (cesantías, primas), and health/pension contributions.
A COP 800,000 monthly 'permanent per diem' costs the employer about 21.5% extra in parafiscals and 9% in social security — roughly 30% above the amount actually paid.
Accidental per diems
An accidental per diem is paid for a specific, non-recurring trip. It does not count as salary and so generates no parafiscals or accruals. But the DIAN requires the trip to be genuinely accidental: a regular weekly visit schedule doesn't qualify.
Reimbursement
Reimbursement is the cleanest fiscal path: pay against receipts, not salary, deductible for the company with a valid electronic invoice, no withholding for the worker. The cost is operational — each expense needs a receipt, a logbook entry, and approval.
For mileage specifically, per-km reimbursement (with a logbook) is the recommended practice. The DIAN does not fix the rate. The Colombian market in 2026 runs COP 800–1,400/km.
Comparison table
| Aspect | Permanent per diem | Accidental per diem | Reimbursement |
|---|---|---|---|
| Counts as salary | Yes | No | No |
| Parafiscals | Yes | No | No |
| Severance | Yes | No | No |
| Withholding | Yes | No (if reasonable) | No |
| Deductible | Yes | Yes | Yes |
| Receipts required | No | Advisable | Mandatory |
| UGPP risk | High | Medium | Low |
What the UGPP looks for
The UGPP (parafiscals enforcement agency) audits classification. Its rule of thumb:
- Regular fixed payments with no receipts → permanent per diem → salary. - Trip-specific variable payments with some receipts → not salary. - Receipt-backed payments → reimbursement → not salary.
Reclassifications produce up to 5 years of retroactive parafiscal adjustments with penalties of 10% to 200% of the omitted amount.
Practical recommendation
For roles with regular travel: combine base salary + per-km reimbursement with a logbook. Reimbursement is deductible, doesn't form salary, generates no parafiscals, and survives UGPP audit. It's the only structure that scales without accumulating labor liability.
The internal policy must be management-signed, dated, and must specify the per-km rate, eligible trips, submission deadline, approval flow, and 5-year receipt archive.