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Costa Rica Considering Taxation of Foreign-Source Passive Income for All Taxpayers

|Proposed Changes|Costa Rica
Costa Rica

Costa Rica published draft Bill No. 25.796 in the Official Gazette on 30 September 2026. Submitted in the Legislative Assembly on 22 September 2026, the draft Bill would expand the rules regarding the taxation of foreign-source passive income. Currently, Costa Rica taxes passive income obtained from abroad by non-qualified entities that are part of an economic group, including Costa Rican entities and permanent establishments in Costa Rica. For this purpose, economic substance requirements a…

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