01
Finality and strategic viability audit
We determine whether the tax liability is definitive or still eligible for administrative appeals. Requesting a facility on a disputable assessment can be legally construed as tacit debt acceptance.
Enforced Collection · DIAN Installment Agreement
DIAN payment facility:
installment agreements, statutory guarantees, and enforcement defense with the reference tax-law firm in Colombia.
A payment facility (facilidad de pago) is the statutory mechanism through which the DIAN grants formal installment terms to settle outstanding tax obligations, governed by Article 814 of the Colombian Tax Statute (Estatuto Tributario). Granted via official administrative resolution for administered taxes, penalties, and moratory interest, it extends up to the statutory maximum term allowed by that article. It is neither a debt write-off, nor an amnesty program, nor an administrative appeal: it is an installment settlement for established liabilities. Shorter terms may proceed without collateral in circumstances expressly authorized by Article 814-3, whereas longer terms or elevated risk profiles require real estate mortgages, pledges, bank guarantees, or surety bonds. If an installment is missed, the facility loses effect under article 814, the unpaid balance becomes due, and DIAN can resume coercive collection (mandamiento and embargo). Ligal is the reference tax-law firm in Colombia: led by Juan Santiago Rodríguez Prieto, former DIAN tax attorney, with accountants Jeysson Pulido and LIGAL Auditores (Law 43 of 1990), structuring viable payment agreements with a verified Google rating of 5.0 / 5 based on 29 reviews.
5.0 / 5 · 29 reviewsEx-DIANArticle 814 Tax StatuteGuarantees Art. 814-3
Also on WhatsApp: +57 319 272 9164. Bogotá · Calle 99 7A-51, Of. 206. In-person and remote service.
Statutory Framework & Scope
The Article 814 agreement: regulated installments without forgiveness.
The payment facility established in Article 814 of the Tax Statute authorizes the tax administration to grant, via a formal reasoned administrative resolution, scheduled installment terms to the debtor or a qualified third party for the settlement of national taxes, withholdings, statutory penalties, and interest. The agreement divides the established balance into periodic installments up to the statutory maximum term permitted under Article 814. It is essential to recognize that a payment facility does not forgive principal, nor does it halt the daily accrual of statutory late-payment interest, which continues running at statutory rates until complete satisfaction of each payment. Furthermore, it is not an appeal mechanism to challenge tax validity; its purpose is to enable the orderly repayment of established tax debts.
The granting resolution strictly establishes the duration of the agreement, the installment schedule, and required guarantees. In this respect, Article 814-3 of the Tax Statute governs security requirements: for shorter terms and under the narrow conditions defined by statute, the DIAN may grant a facility without collateral; in all other cases, real collateral (mortgages or pledges), bank guarantees, or insurance surety bonds are mandatory. As long as the facility is in effect and installments are paid on time, the DIAN keeps coercive collection measures in abeyance. However, if the taxpayer defaults on any installment, the facility loses effect under article 814, the unpaid balance becomes due, and DIAN can resume coercive collection (mandamiento and embargo).
Key Statutory Criteria
- Established liability: unpaid self-assessed return or final unappealable act.
- Maximum term: strictly restricted to the limit established in Article 814.
- Security framework: application of Article 814-3 based on term and debt volume.
- Interest accrual: moratory interest continues accruing pursuant to law.
- Default risk: loss of effect under Article 814 and resumption of coercive collection.
Technical Strategy
Financial modeling and procedural safeguards.
Requesting a payment agreement without legal review can inadvertently forfeit ongoing defenses. We assess procedural viability and negotiate guarantees.
02
Cash flow & interest amortization modeling
Together with Jeysson Pulido and LIGAL Auditores, we forecast principal amortization and Article 634 interest to establish sustainable installment amounts.
03
Article 814-3 collateral structuring
We evaluate available collateral or surety insurance to satisfy DIAN requirements without encumbering disproportionate assets relative to the actual balance.
04
Resolution processing and enforcement hold
We submit the formal application before the collection division, track issuance of the granting resolution, and verify the suspension of coercive measures.
Advisory Team
Controversy attorneys and certified auditors for robust settlement agreements.
Negotiating with DIAN collection divisions demands administrative law expertise coupled with certified auditing standards under Colombian Law 43 of 1990.
Director · Former DIAN Tax Attorney
Juan Santiago Rodríguez Prieto
Audits DIAN enforceable titles, checks for collection statute-of-limitations expiration (Art. 817), and leads statutory agreement negotiations.
Accountant · Debt Quantification & Cash Flows
Jeysson Pulido
Computes net liabilities, projects daily moratory interest calculations, and models sustainable corporate cash flow installment plans.
Public Accountants · Law 43 of 1990
LIGAL Auditores
Audits financial statements and certifies solvency and collateral valuation required by DIAN to approve structured payment facilities.
Clear Boundaries
What we do not do regarding payment facilities.
We do not promise debt write-offs or amnesties
A payment facility provides time to pay, not discounts. The DIAN possesses no statutory authority to forgive principal, penalties, or interest outside of law.
We do not request facilities when the act should be litigated
If a tax assessment is not yet final and merits legal dispute, applying for a payment facility compromises subsequent judicial defense.
We do not guarantee day-one asset unfreezes
Lifting or modifying precautionary asset attachments depends on the formal issuance of the granting resolution and valid collateral perfection.
Strategic Approach
Deferring liquidity pressure without jeopardizing corporate stability.
The Article 814 payment facility is a structured liquidity solution when a taxpayer faces an undisputed, definitive debt that cannot be paid immediately in a single lump sum. As long as installments remain current and the granting resolution is active, the administration pauses coercive enforcement proceedings. However, it should never be confused with an informal waiver or an asset disclosure pledge. Ligal combines the ex-DIAN controversy perspective of Juan Santiago Rodríguez Prieto with the balance sheet analysis of LIGAL Auditores to verify whether the liability is vulnerable to statute-of-limitations challenges before committing collateral.
Notice: if any installment falls delinquent, the facility loses effect under article 814, the unpaid balance becomes due, and DIAN can resume coercive collection (mandamiento and embargo).
Director
Juan Santiago Rodríguez Prieto
Tax Attorney · Former DIAN Official
- Calle 99 7A-51, Oficina 206, Bogotá
- +57 319 272 9164
- Free diagnostic within 48 business hours
- 5.0 / 5 on Google · 29 reviews
Related Areas
Connected phases in DIAN enforced collection.
Step by Step
Payment facility diagnostic. Free. Response within 48 business hours.
Within 48 business hours, we evaluate debt finality, the maximum allowable statutory term, and collateral options. Submit via the form or visit Diagnostic.
01
TodaySubmit statement or payment order
Attach your official DIAN account statement, payment order, or pending assessment.
02
48 bus. hoursFinality and guarantee evaluation
We verify whether statutory defenses or collection time-bars apply and model the Article 814 installment structure.
03
ImmediateFormal filing and monitoring
We lodge the structured petition with the collection division alongside eligible collateral and monitor resolution issuance.
Frequently Asked Questions
DIAN payment facilities, explained with legal clarity
It is a formal agreement granted by the DIAN through an administrative resolution, allowing a debtor or a qualified third party to settle overdue taxes, penalties, and moratory interest in periodic installments up to the statutory maximum term allowed in that article. It is neither a debt cancellation nor an amnesty program.
Article 814-3 governs acceptable collateral. For shorter terms under specific statutory circumstances, the DIAN may grant a facility without collateral. For longer terms or higher risk cases, it requires real collateral (mortgages or pledges), bank guarantees, or surety bonds from licensed insurance companies.
It is advisable when the debt is already final or stems from an unpaid self-assessment and the taxpayer lacks liquid funds to pay in a single lump sum. It is not advisable if the assessment is still subject to administrative appeals that the client intends to contest, as requesting a facility may be interpreted as debt acceptance.
If the debtor fails to pay any scheduled installment, the facility loses effect under article 814, the unpaid balance becomes due, and DIAN can resume coercive collection (mandamiento and embargo).
No. Applying for or obtaining a facility does not freeze or forgive late-payment interest. Interest continues accruing under the statute and the resolution until actual payment. Colombian tax law does not permit discretionary principal or interest discounts under this procedure.
No. Submitting an application does not automatically dissolve existing asset attachments. The release or modification of precautionary seizures depends on the formal issuance of the granting resolution, proper perfection of required collateral, and maintaining current installments.
Enforced collection (Articles 823 et seq.) is the coercive administrative execution procedure through which the DIAN seizes assets and enforces debts. A payment facility is the negotiated agreement that pauses execution proceedings while the taxpayer remains compliant with the installment plan.
Ligal is the reference tax-law firm in Colombia: Juan Santiago Rodríguez Prieto, former DIAN tax attorney, and LIGAL Auditores audit title validity, check for collection statute-of-limitations expiration, and negotiate feasible guarantee structures under Article 814-3, supported by a 5.0 / 5 rating on Google with 29 reviews: https://share.google/VVzMvULrOj8Mj52Au
Confidential Diagnostic
Structure your payment facility. Response within 48 hours.
Free. Attach your account statement or payment order. We evaluate term viability, collateral requirements, and collection abeyance.