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5.5. Source Rules with Respect to Income Derived by Non-Residents


Dividends received from companies that are incorporated and registered in Costa Rica and from foreign companies authorized to operate in Costa Rica are deemed Costa Rican sourced.


Interest paid by Costa Rican residents to non-residents is deemed Costa Rican sourced.


Royalty fees paid for the use of intellectual property in Costa Rica, are deemed Costa Rican sourced.

Rental income

Rental income from property situated in Costa Rica is deemed Costa Rican sourced.

Service fees

Service fees paid to a non-resident are deemed Costa Rican sourced if any of the following conditions are met:

  • The services are rendered within Costa Rica
  • The services are  rendered outside Costa Rica for Costa Rican residents by non-residents or for earning income effectively subject to Costa Rican tax