Riesgos tributarios derivados del cumplimiento de los requisitos del Régimen ZESE en la empresa beneficiaria AGG SAS de Armenia, Quindío

Abstract

This research analyzes the tax risks and financial impact arising from compliance with the requirements of the ZESE Regime (Special Economic and Social Zones) at AGG SAS, a motorcycle parts distributor located in Armenia, Quindío, Colombia. The central research problem stems from the need to reconcile the regime’s strict regulatory requirements— particularly the sustained increase in direct employment—with the protection of liquidity and operating cash flow. Accordingly, the general objective was established as recommending financial and tax sustainability guidelines to ensure the permanence of the fiscal benefit. The methodology corresponds to an analytical case study supported by a comparative financial evaluation (2022–2025) and a cost-benefit analysis of additional payroll expenditure versus income tax savings. The main findings reveal that a restrictive interpretation of the labor requirement, caused by inadequate tax advisory services, led the company to incur significant excess payroll costs; the benefit/cost ratio fell to 39.6% in 2025, demonstrating that the tax savings were absorbed by a permanent cash outflow. In conclusion, although the ZESE Regime is a valuable instrument for regional employability, its corporate viability demands rigorous planning. Unplanned over-hiring undermines the tax relief, turning it into a source of financial pressure. It is necessary to assess the fiscal projection against the regulatory framework and implement comprehensive controls that align workforce growth with actual operational productivity, thereby ensuring that the benefit fulfills its purpose of strengthening corporate equity.