Temporary employment services, comprehensive cleaning and cafeteria services and security and surveillance services.

On August 30 of this year, DIAN reconsidered Concept 005224 of 2026, clarifying the special AIU tax base for withholding tax purposes.

The tax base for withholding income tax on temporary employment services and the comprehensive cleaning, cafeteria, and surveillance services covered under Article 462-1 of the Tax Statute is analyzed as follows:

1. Previous concepts held that: (i) Article 462-1 of the Tax Statute applied solely to determine the VAT tax base; (ii) withholding tax had to be levied on the total value of the payment or credit to account; (iii) the minimum threshold of 2 UVT had to be verified against the total value of the payment or credit to account; and (iv) the corresponding rates had to be applied likewise to the total value.
2. Consequently, a reconsideration of existing doctrine was requested because it failed to account for the scope of Paragraph 1 of Article 462-1 of the Tax Statute, which expressly extends the application of the special tax base provided therein to withholding tax.

Therefore, it is determined that the rule governing the base for applying withholding tax on temporary employment services and services rendered by cleaning and/or security companies is Article 462-1 of the Tax Statute, as it holds superior hierarchy over Article 1.2.4.4.10 of Decree 1625 of 2016, which is a regulatory decree.

DIAN concludes:

The special tax base outlined in Article 462-1 of the Tax Statute applies for levying income tax withholding on comprehensive cleaning and cafeteria services, surveillance services, and temporary services, subject to the conditions established therein.

Consequently, the rates set forth in Article 1.2.4.4.10 of Decree 1625 of 2016 must be applied to the AIU component, which cannot be lower than 10% of the contract value.

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