If you own, plan to buy, or finance property in Costa Rica, and you also hold assets or earn passive income abroad, October 2025 marks a practical turning point. Costa Rica’s new integrated tax platform, TRIBU-CR, goes live on October 6, 2025, with a data cut and migration beginning September 25, 2025. This upgrade gives the Tax Administration far greater ability to match information across systems and with data received from abroad, tightening oversight of undeclared assets and passive income.

• TRIBU-CR centralizes tax data and supercharges information matching, including the use of international data already flowing to Costa Rica through cooperation frameworks. Expect more cross-checks and fewer blind spots.

• Since October 2, 2023, Costa Rica taxes certain foreign-source passive income (e.g., interest, dividends, capital gains, royalties, and capital income) at a general 15% rate, with potential credit for tax paid abroad; special “qualified entity” rules apply to certain multinational groups. Individuals are not covered by that group exception. The 2023 reforms still apply—none of them are obsolete. What’s new in 2025 is TRIBU-CR, a tech platform that improves detection and cross-checks; it does not replace the 2023 rules.

• The new system is designed around the OECD’s BEPS pillars—coherence, substance, transparency—so mismatches between what you declare and what third-party data shows are more likely to be flagged.

To comply with international standards and exit EU scrutiny, Costa Rica reformed its territorial tax approach in Law 10,381. This law was effective upon publication in La Gaceta on October 2, 2023. The reform extends tax to passive income earned abroad, generally at 15%. It allows a foreign tax credit for similar taxes paid in the source country (up to the Costa Rican tax due on that income). These rules interact with new substance criteria for “qualified entities” in multinational groups. If an entity does not qualify, the passive income rules apply in full.

For individuals: Residents of Costa Rica with passive income from outside the country (for example, dividends from foreign companies or interest from overseas accounts) generally fall under the 15% regime, with the credit mechanism available for tax actually paid abroad. This is a notable shift for globally invested families relocating to Costa Rica or splitting time here.

(2023 law) If you are a Costa Rica tax resident, foreign rental income and related capital gains can be taxable. In Costa Rica, it’s generally at 15%, with a potential foreign tax credit for comparable taxes paid abroad (capped by the CR liability). Keep leases, management reports, bank statements, closing statements, and proof of foreign tax paid.
(2025 platform) TRIBU-CR increases the likelihood that declared rents and gains are cross-checked against third-party and international data (e.g., statements from property managers, bank transfers, and foreign filings).

(2023 law) Dividends, interest, fund distributions, and capital gains earned abroad are generally taxed at 15% for Costa Rica tax residents, with a credit for eligible foreign taxes.
(2025 platform) Expect automated reconciliation between what you file and what arrives via international information exchange (financial institution reports, custodial statements).

(2023 law) Only “qualified entities” in multinational groups that meet objective substance criteria may receive different treatment. Otherwise, the passive-income rules apply in full. If you rely on an offshore entity for investments, have advisors test it against the objective substance parameters issued by the Tax Administration in late 2023.
(2025 platform) TRIBU-CR strengthens relationship mapping (beneficial ownership, intercompany flows), making substance mismatches and unsupported structures easier to spot.

(2023 law) Authorities may examine the source of funds; unexplained increases in wealth can trigger legal presumptions and assessments. Maintain clear trails (sale proceeds, dividends, loan agreements, remittance proofs).
(2025 platform) With broader data correlation, transfers used in a purchase can be matched to foreign accounts and documents. This raises detection risk if the origin isn’t well-documented.

• Sept 25, 2025 – Database “cut” for migration to TRIBU-CR (late evening).

• Oct 6, 2025 – TRIBU-CR goes live; new e-invoicing version activates the same day; certain September VAT deadlines are pushed accordingly.

BEPS (Base Erosion and Profit Shifting) is the OECD’s framework of 15 actions that push countries to close gaps used to shift profits across borders. The three pillars—coherence, substance, transparency—explain why Costa Rica now taxes foreign passive income. It also explains why TRIBU-CR focuses on data matching. In short, the story your documents tell needs to be consistent everywhere.

• Confirm your tax residency and family members’ status; residency drives exposure to tax on foreign passive income. (Your immigration plan and days in-country matter.)

• Inventory global assets: properties, portfolios, entities, and accounts. Identify all passive income streams since October 2023.

• Collect paperwork: purchase/sale deeds, rental ledgers, brokerage 1099-equivalents, bank interest statements, and proof of foreign taxes paid to support the Costa Rican credit.

• Evaluate structures: if you use entities, test substance (people, decision-making, costs) against the 2023 resolution. Adjust governance where needed.

• Regularize omissions early: once TRIBU-CR is active, detection risk rises; proactive compliance is safer (and often cheaper) than waiting.

This article is for general information only and doesn’t constitute tax, legal, or accounting advice. For personalized guidance, consult with The Agency Costa Rica to link you with specialized professionals.