Costa Rica Foreign Income Tax Bill Aims at Investments Abroad
COSTA RICA · TAX
Key Facts
- —What happened The Ministry of Finance filed a bill to tax five kinds of foreign investment income.
- —The rate A flat 15% would apply to foreign interest, dividends, royalties, rents and capital gains.
- —Who is covered Costa Rican tax residents, including people and entities that run no business here.
- —Not listed Pensions and salaries are not among the five categories in the filed text.
- —The catch The bill is only filed, with no committee vote, and its wording can still change.
- —What comes next The Legislative Assembly must send the bill to a committee before any debate.
The Ministry of Finance filed a bill that would tax five kinds of investment income earned outside the country by residents.
A new Costa Rica foreign income tax bill would charge 15% on five kinds of investment income earned abroad. The Ministry of Finance filed it on Tuesday 22 September 2026, and it is not law.
What the Costa Rica Foreign Income Tax Bill Covers
The Ministry of Finance, known in Spanish as the Ministerio de Hacienda, filed the measure as expediente 25.796. That is the file number the Legislative Assembly gives a bill.
The text sets a general rate of 15% on five categories earned abroad. They are interest, dividends, royalties, rents and capital gains.
It defines foreign passive income as income from property and capital, plus capital gains, from assets held or used outside the country. Capital losses on those foreign assets could not be counted.
Those covered are people, companies, trusts, investment funds and similar structures resident in Costa Rica. The rules would reach residents even if they run no business in the country.
The Vice-Minister of Revenue, Víctor Julio Carvajal, said the plan is part of a drive against tax evasion and smuggling. He said it would close gaps that have stood for years.
Pensions and Salaries Are Not on the List
Foreign pensions and salaries do not appear among the five categories in the filed text. The definition in the bill reaches investment and property income, not pay for work.
The government says the country would not move to a worldwide income system. Territorial rules would stay in place, with a wider exception for passive income from abroad.
Salary for remote work paid from abroad is not named in the text either. How any single payment is treated would still depend on how Costa Rican law classifies it.
No minimum amount or exempt threshold has been reported, and no start date has been set. Those points would only become clear in a final law.
The same bill would also scrap a tax credit for issuers of themed public securities. That change matters mostly to companies, not to individual residents.
How It Meets the 183-Day Residence Test
The central test in the bill is tax residence, not nationality. Costa Rica treats a person as tax resident after more than 183 days in the country.
Being a tax resident does not by itself make all foreign income taxable today. The country still taxes income from Costa Rican sources as its general rule.
The bill would change that in one place only, for foreign passive income of residents. Everything else would stay under the territorial rule, on the text as filed.
A separate Rio Times guide sets out how the 183-day residence test works. The bill does not appear to rewrite that test.
Why This Matters for Expats and Investors
Many foreign residents in Costa Rica live on money that arrives from outside. The bill would touch the investment part of that money, not the pension part.
A tax resident with a rented flat abroad, or shares paying dividends, could fall inside the rules. The text offers relief for tax already paid or withheld in the other country.
That relief would work differently from the current system. The taxable sum would be the gross amount received minus the foreign tax, with the 15% rate applied after that.
What is not known is the final wording, any start date and any exclusions. Anyone affected should take advice from a qualified tax professional on their own position.
It is also not known how the plan would sit with tax treaties or with rules in a reader’s home country. Those answers depend on each person’s own facts.
The 2023 Fight Behind the Bill
Costa Rica already taxes some foreign passive income under Law 10.381, in force since 2 October 2023. That law only reaches firms in multinational groups that lack real substance here.
Lawmakers overrode a partial veto by then president Rodrigo Chaves on 26 September 2023, by 38 votes to 15. The European Union then took Costa Rica off its list of non-cooperative jurisdictions.
The ministry argued at the time that the version passed would cost about ₡10 billion (US$22 million) a year. Figures use 23 September 2026 rates, about 447 colones to the dollar.
Chaves is now Minister of the Presidency and Finance under President Laura Fernández. Both signed the new bill, which drops the multinational group and substance conditions.
The reasoning filed with the bill says two residents with identical foreign dividends can be taxed differently today. It says the outcome turns only on the structure through which the money arrives.
What Happens Next
Both the tax bill and a companion bill on exemptions must go to a committee before debate. The Assembly’s finance committee is the likely destination, and it is now reviewing the 2027 budget.
A separate bill from the Frente Amplio party, expediente 25.734, is already in that committee. It was filed on 20 August 2026 and uses a different formula.
Rates, scope and start dates often change as bills move through the Assembly. For now nothing has changed for residents with income abroad.
Frequently Asked Questions
Would the bill tax my foreign pension?
Pensions are not among the five categories in the filed text, which covers investment and property income. The wording could change during debate.
Is the 15% rate in force now?
No. The bill was filed on 22 September 2026 and has not been debated or approved.
Who would be covered?
Tax residents of Costa Rica, including individuals, companies, trusts and investment funds that own income-producing assets abroad.
Connected Coverage
Costa Rica Tax Residency and the 183-Day Rule, Explained for 2026
Costa Rica Permanent Residency and Citizenship: The 2026 Rules
Sources: Ministerio de Hacienda bills expedientes 25.796 and 25.797, filed in the Legislative Assembly on 22 September 2026; Delfino.cr; La Nación; CRHoy; Teletica; El Mundo CR; Monumental.
This article was produced by The Rio Times’ automated newsroom system. How we use AI · Report an error
Read More from The Rio Times