Tax in Costa Rica


The powerhouse team at Arias remains a market leader, advising investors and major multinationals on the establishment of tax structures and administrative and judicial cases against the tax authorities. Tax group head Caroline Flores brings extensive experience to assisting clients with risk management and regulatory compliance matters. International trade and foreign investment practice head Carlos Camacho advises companies on the free trade zone regime and investors across the telecoms, infrastructure, real estate, pharmaceuticals, and retail sectors. Senior counsel Ligia Alfaro provides support in complex tax litigation.

Responsables de la pratique:

Carolina Flores; Carlos Camacho

Les références

‘One of the most solid and complete teams in the country. Its expertise goes beyond the technical to the legal level. They have achieved an excellent balance with the accounting and financial areas, which allows them to provide real, feasible recommendations and solutions, aware of the implementation opportunities that customers have.’

‘Unsurpassed technical and business knowledge, providing real and implementable solutions.’

Principaux clients



Principaux dossiers

  • Advised Spanish multinational telecoms company Telefonica on the sale of its Central American operations, providing the regulatory analysis needed to obtain permits for the transaction.
  • Assisted US-based manufacturing company Micro with its incorporation in Costa Rica, services, and free trade zone procedure.

Consortium Legal

The tax team at Consortium Legal continues to be a leader in the practice area, assisting banks and non-bank lenders and local, regional and multinational corporations (including household names such as Uber, Walmart and Del Monte) on high-value, cross-border transactions, transfer pricing, judicial and administrative litigation, customs processes and major infrastructure projects, including toll road and port concessions. The practice is headed by Diego Salto, who brings over 27 years in tax consulting work to the team, along with Rafael Luna, an expert in transfer pricing. Anayansi Mora co-ordinates the tax litigation group, with senior associate Felipe Guevara providing support on concession projects throughout the region. The team’s client base spans the real estate, energy, health, food, retail and logistics sectors.

Responsables de la pratique:

Diego Salto; Rafael Luna

Principaux clients



Del Monte








Principaux dossiers

  • Advising Cemex Group on all tax-related issues in connection with the sale of Cemex Costa Rica to Cementos Progreso in Guatemala.
  • Assisted Del Monte in a tax administration collection process related to an assessment of approximately $92m on a transfer pricing matter.
  • Advised private financial institution BAC on several tax matters, including a procedure before the tax administration.

EY Law Central America

With seven offices across Latin America, the practice at EY Law Central America leverages its regional strength and the experience of its team to provide advice on complex tax issues to major national and multinational corporations involved in high-value transactions. Rafael Sayagués, who is managing partner of the tax and legal Central America, Panama and Dominican Republic regional practice, brings longstanding expertise to M&A, tax litigation, project finance and corporate restructuring matters. International tax service leader Juan Carlos Chavarría brings over 25 years of tax planning experience to advising clients in the insurance, oil and gas, and consumer products sectors. Antonio Ruiz Rojas, who leads the transactional tax and tax controversy practice in Central America, Panama and the Dominican Republic, specialises in the tax due diligence aspects of cross-border deals. Indirect tax, customs and global trade director Carolina Palma manages matters relating to free trade zone structuring and compliance.

Responsables de la pratique:

Rafael Sayagués

Les références

‘They have a regional presence, with teams of renowned professionals both locally and regionally.’

Principaux clients

Cementos Progreso


Principaux dossiers

  • Acted as transactional tax adviser to Cementos Progreso throughout the entire process of its $335m acquisition of Cemex’s operations in Costa Rica and El Salvador.
  • Acted as transactional tax adviser in Costa Rica, Panama, Nicaragua, Honduras, El Salvador and Guatemala to AkzoNobel in its acquisition of Colombia-based paints and coatings company Grupo Orbis.

Facio & Cañas

The tax team at boutique firm Facio & Cañas takes a multidisciplinary approach to assisting major national and international corporations, banks and insurers with high-value investments, corporate restructuring, M&A, compliance and litigation. Department founder and finance and tax law expert Adrián Torrealba leads the team, along with José María Oreamuno, a specialist in contentious administrative matters, associate Modesto Vargas, who brings experience of working for the Costa Rican Treasury, and tax manager Erik Ramirez. The team’s client base includes household names Del Monte and British American Tobacco, and spans the banking and finance, agriculture, food, tobacco, retail and tech sectors.

Principaux clients

Durman Esquivel

Colorado Tarpón

Banco de Costa Rica

Del Monte


Floride Ice and Farm

British American Tobacco




Principaux dossiers

  • Advising Durman Esquivel in a contentious-administrative lawsuit over the application of the unjustified increase of wealth tax.
  • Supporting Del Monte in two contentious-administrative lawsuits regarding the use of transfer pricing methods for the fiscal years 2012-2015 and 2016.
  • Representing two subsidiaries of Florida Ice and Farm (a beer producer in Costa Rica) in two contentious-administrative proceedings.

Aguilar Castillo Love

In addition to a strong track record of handling the tax aspects of high-value M&A and joint ventures for global household names (including Coca-Cola and Hewlett-Packard), the team at regional firm Aguilar Castillo Love specialises in complex administrative tax litigation. Department head José Pablo González, who has extensive in-house experience (having served as Walmart’s tax counsel in Costa Rica), maintains a focus on compliance matters and has overseen substantial growth on the contentious side of the practice. With a client base spanning the real estate, tech, automotive and beverages sectors, the team’s comprehensive practice extends to transfer pricing, tax credits, advance pricing agreements and exemptions.

Responsables de la pratique:

José Pablo González

Les références

‘Jose Pablo Gonzalez is always available and helps us find a comprehensive solution. In addition, he cares that we are satisfied with the options he offers us and investigates further if necessary.’

‘The customer service response is spectacular and knowledgeable.’

Principaux clients

Hewlett-Packard Enterprise

The Coca-Cola Company

Brenntag (Químicos Holanda Costa Rica)


Seaboard Marine

Johnson Controls

Weston Foods

Andes Chemical Corporation

Assa Abbloy


Principaux dossiers

  • Advised Weston Foods on all the tax aspects involved in the sale of its Costa Rican subsidiary to a third party.
  • Advised Johnson Controls on the acquisition of Costa Rican heating, ventilation, and air conditioning (HVAC) company Lucas Ingenieros.
  • Represented Químicos Holanda in the first stage of the administrative proceedings that followed audit procedures conducted by the Costa Rican Tax Administration, and as a result, no additional tax amount was levied.

Alta Batalla

The tax team at Alta Batalla, now a regional player following its May 2021 merger with firms in Guatemala, Honduras and El Salvador, advises local and international corporations on the tax aspects of M&A, restructurings and foreign direct investments, in addition to providing support on free trade zone matters, compliance reviews and tax litigation. Róger Guevara is the key contact.


Utilising its regional bench strength, the experienced team at BLP represents local corporations and major multinationals involved in contentious proceedings against the tax authorities. Tax director and department head Vittoria Di Gioacchino advises clients in the telecoms, real estate, retail and pharmaceuticals sectors on due diligence, M&A transactions and transfer tax matters. Special counsel Luis Chacón brings over 30 years of tax litigation experience to the practice. Senior associate Isis Ulloa and tax consultant Tatiana Chacon are also key contacts.

Responsables de la pratique:

Vittoria Di Gioacchino

Les références

‘They have a lot of skill in Costa Rican tax issues.’


The team at ECIJA provides national and international corporations with comprehensive advisory services covering tax contingencies analysis and planning and representation before administrative tribunals and in judicial proceedings. Experienced litigator Mariela Hernández leads the practice, specialising in the annulment of fines on administrative contracts and tax adjustments. Utilising the custom Virtual ECIJA meeting platform, the team assists a broad span of clients across the real estate, beverages, energy and tourism sectors.

Responsables de la pratique:

Mariela Hernández

Les références

‘ECIJA has a solid team and impressive knowledge of the tax area.’

‘The ECIJA team is highly qualified in legal tax issues in the region and is very efficient in its recommendations, always responding on time.’

Principaux clients

Coca Coca Femsa

Union Fenosa Generadora La Joya

Ecodesarrollo Papagayo

Grupo Istmo de Papagayo

Principaux dossiers

  • Succeeded in halting the municipality of Liberia from increasing a royalty fee that Ecodesarrollo Papagayo has to pay on its concession over a specific area next to the beach line in Costa Rica.
  • Continuing to act as tax counsel for Coca Cola Femsa, providing tax advice in connection with the company’s business and transactions.
  • Engaged on behalf of Union Fenosa Generadora La Joya in the execution of a favourable court ruling following a long-running suit against the state for certain VAT tax credits that the tax administration had refused to accept following an audit.

Sfera Legal

The experienced tax team at Sfera Legal designs tax structures for multinational corporations involved in cross-border investment projects and represents clients in high-stakes tax litigation. Led by co-founding partner Eric Scharf, an expert in tax and corporate law, the team’s client base spans the pharmaceuticals, insurance, fintech and hospitality sectors. The group is supported by co-founding partner Robert Van Der Putten and tax director Pablo González, an experienced specialist in overseas investments.

Responsables de la pratique:

Eric Scharf

Les références

‘Transparency, immediate attention, commitment.’

Principaux clients


Establishment Labs

Punta Norte

Gilded Iguana Hotel

Wyde Corporation

Opti Prime Properties

Infotur Data Solutions


Corporación AGP Costa Rica

Humaan Collective

DOC Virtual Medicine

SMART Masterdealer

Void CR

Principaux dossiers

  • Advising the Humaan Collective investment project in Costa Rica on its legal and tax structure.
  • Assisting Corporation AGP in the design and implementation of a more tax-efficient business structure.
  • Assisting payment network Zunify Payments with implementing its investment structure and optimising the complex treatment of intangibles.