Tax domicile and Costa Rican-source income

Domicile includes more than 183 days

Individuals are domiciled for income tax when present for more than 183 days, continuously or not, in the relevant fiscal period, including entry and exit days. Sporadic absences up to 30 consecutive days count unless foreign tax residence is certified; longer absences do not.

The period and official-service rules matter

For income taxes other than the profits tax with nonannual assessment periods, the presence window is the twelve months before assessment. Individuals holding official posts or representations abroad paid by Costa Rica's state, public bodies or municipalities are also treated as domiciled.

Source, not nationality, is central

The profits-tax baseline covers domestic-source activity. The law defines Costa Rican source by services performed, assets situated, capital invested and rights used in national territory, independently of nationality or domicile. Capital-income and realised-gain taxation also follows the statutory territorial definition.

Foreign passive-income reform is limited

The exception for listed foreign passive income applies to nonqualified entities belonging to multinational groups. Article 27 otherwise excludes the relevant capital income generated abroad, even with Costa Rican-source capital. This is not a general worldwide-income rule for resident individuals.

Nonresidents can still owe source tax

Costa Rican-source income paid, credited or made available to foreign-domiciled recipients can trigger outward-remittance tax and payer obligations. Capital gains of non-domiciled owners instead follow the capital-gains chapter, with applicable withholding, rather than automatically the remittance-tax rules.

Treaty relief is not automatic

Hacienda's treaty guide requires an effective applicable convention, the appropriate income article and evidence of tax residence for the relevant period. A treaty does not mean total exemption; the taxpayer must establish entitlement and retain supporting evidence.