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10.1. Holding Regimes

There is no specific tax-driven holding regime. Note that there is a dividend withholding tax on dividends paid to non-residents, whilst dividends by a resident shareholder from a resident company are generally tax-free. Capital gains are not taxable unless habitual in nature or realized on depreciable assets. The table below summarizes the key rules relevant to establishing a holding company in Costa Rica:

Is there a special tax regime for holding companies? No
Are there substance requirements? No
Are there restrictions on activities? No
Are advance rulings available? Yes - A taxpayer can request a  private letter ruling from the Tax Administration on the tax consequences of a current transaction.
Is capital duty payable? Yes - Several stamp taxes are payable when capital contributions or returns of capital are made.