Costa Rica: corporate tax guide

What the tax system covers

The ordinary profits-tax base is Costa Rican-source income. Law 10381 adds specified foreign passive income for nonqualified entities belonging to multinational groups. The source-based label must retain this exception and the substance test behind it.

When a company becomes tax resident

For an operating company, identify its legal form, domicile and any local permanent establishment before determining the taxable base. A foreign enterprise can have a taxable Costa Rican operation without becoming a locally incorporated company. The detailed domestic residence classification should be checked against the current statute for the particular entity.

Rates and the tax base

30% ordinary company income tax. Qualifying companies with 2026 gross income no higher than CRC119,174,000 instead apply graduated 5%, 10%, 15% and 20% rates to net taxable income. The gross-income eligibility ceiling differs from the net-income bands. Free-zone incentives and startup reductions require separate qualification.

Outbound dividends, interest and royalties

Dividends: 15%; 5% specified statutory categories. Article 59(g) remittance treatment refers to distributions under articles 18 and 19, with 15% or 5% depending on the statutory category. Establish which distribution qualifies rather than treating 5% as the general rate.

Interest: 15% ordinary financial payments. Article 59 applies 15% to ordinary outbound interest, commissions and financial expenses. Specified regulated financial institutions and development lending can have different rates or exemptions. The reduced 5% category must not be used as the rate for every foreign lender.

Royalties: 25%. Article 59(j) covers rights payments including patents, formulas, trademarks, franchises and royalties, and specified advice. Classification and treaty entitlement require their own review.

Local business income does not inherit a blanket exemption

Law 9996 expressly preserves income tax on income generated in Costa Rica from local investments. It also states that holding the qualifying immigration category does not automatically make the holder a tax resident. These are distinct questions even where a particular qualifying income enjoys an exemption.

For a founder, map work location, customer location, employees, invoicing and distributions. Digital-nomad treatment concerns the approved remote-worker arrangement; it should not be transferred to an unrelated local company or to income outside the programme. Departure from the current country must be established under that country’s rules as well.

Foreign passive income and a multinational group

The 2023 amendment identifies dividends, interest, royalties, capital gains and specified property or movable-capital income from abroad where a nonqualified entity belongs to a multinational group. This is an exception to the ordinary source framework. Establish group membership, the type of income and qualified-entity status before relying on territorial treatment.

Withholding and foreign tax relief are separate calculations

The statute provides rules for remittances of Costa Rican-source income to persons domiciled abroad and rules for crediting relevant foreign tax on covered foreign passive income. Record the gross amount, payment category, recipient and tax paid. A foreign-tax credit is limited by the applicable domestic calculation; it is not an unlimited refund of every tax paid overseas.

An annual company charge is separate from profit tax

Hacienda's 2026 notice covers an annual legal-person tax for registered companies, foreign branches and specified individual limited-liability enterprises. Its calculation depends on the statutory base salary and activity/income category, including a charge for inactive companies. These percentages are not corporate income-tax rates on profit. Keep this annual charge separate from the income-tax return and other registrations.

Foreign companies and income attribution

No categorical conclusion is published in this draft; foreign-income and entity substance rules need a separate current-law review.

Departure, migration and continuing obligations

Personal departure and corporate asset transfers must be analysed separately; no universal no-tax claim is made.