Treasury to Reveal Major "Zero-Profit" Taxpayers in Costa Rica

EY Law | In compliance with the new Fiscal Transparency Law No. 10808, EY Law informs of the Ministry of Finance’s new obligation to annually publish the list of large taxpayers reporting zero profits or losses.

This obligation was established in the Fiscal Transparency Law No. 10808, published in Supplement No. 158 of Official Gazette No. 233 on December 11, 2025, and effective from that same date.

The law amended Article 115 of the Tax Code (CNPT) to require the Tax Administration to publish, once a year, a list of large national taxpayers who reported losses or zero profits in the previous fiscal year.

The list must expressly include the name and identification number of each taxpayer, and be published on a publicly accessible digital platform managed by the Ministry of Finance.

When should the first list be published?

The sole transitional provision of the law establishes that the first publication of the list must take place within 12 months of its entry into force, that is, no later than December 11, 2026.

Reminder for Large National Taxpayers Anticipating Losses or Zero Profits in Fiscal Year 2025 In addition to the annual publication of the list, large national taxpayers who anticipate losses or a zero tax liability are reminded that they must submit audited financial statements, without prior request from the Tax Administration, within three months of the close of the corresponding fiscal year, in accordance with current Resolution No. DGT-R-046-2014.

eylaw.com