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11.1. Direct and Indirect Tax Consequences of Re-Organizations

Costa Rican income tax law does not provide specific rules with respect to mergers and demergers. On the other hand, Tax Administration has established that the transfer of immovable property within a merger is not subject to tax on the transfer of immovable property.

Capital gains arising from the transfer of shares, on the other hand, are only taxed if considered as resulting from a habitual activity of the shareholder.