Costa Rica: Tax Administration Clarifies VAT Rules for Free Zone Companies

EY Law - Through official document MH-DGT-CONS-119-0063-2025 (dated September 18, 2025, as provided in the original text), the Tax Administration clarified to a taxpayer, whose company is subject to the Free Trade Zone (FTZ) regime, whether they are required to:

• Perform the reverse charge (self-reversal) calculation for the acquisition of intangible goods or services from suppliers not domiciled in the national territory.Mandatorily use electronic purchase invoices for the acquisition of these same services from companies under the FTZ regime.

• Mandatorily use electronic purchase invoices for the acquisition of these same services from companies under the Free Trade Zone regime.

In this regard, the Tax Administration clarifies that companies under the FTZ regime are not required to perform either the reverse charge calculation or issue the corresponding electronic purchase invoice for the acquisition of intangible goods or services from suppliers not domiciled in the national territory.

The Tax Administration’s Rationale

The Tax Administration’s response to the taxpayer outlines the following:

"Thus, it is clear from the transcribed regulations that companies under the Free Trade Zone regime maintain their sales tax exemption on purchases of goods and services. Therefore, since they are not taxpayers of this tax at the time of making purchases, they are not required to issue the electronic receipts established in Article 3 of the Electronic Receipt Regulation (RCE). It should be noted that the VAT exemption applies only to purchases of goods and services, and does not extend to domestic sales transactions made by the requesting party.

Therefore, regarding the first question, the requester is not required to reverse the taxable person’s tax liability (self-reversal) when purchasing intangible goods or services from suppliers not domiciled in the national territory, given that the requester is