Rules on amnesty for corporate income tax amnesty Resolution DGT-R-26-2022 in Costa Rica

Law 10220 amended Transitory ll of Law 9428 so that taxpayers of the Corporate Income Tax, who since September 1, 2017 and until December 15, 2022 have paid the amounts due under Law 9024, may pay the periods due from 2017 to 2021, without having to pay the corresponding interest or penalties.

In this context through this joint Resolution of the DGT and the Registry it has been specified that:

For the purposes of this resolution, “taxpayer” is understood as any of the commercial companies, as well as any branch of a foreign company or its representative and the individual limited liability companies that are subject to the Tax on Legal Entities.

Prior payment of tax debts, up to and including the period 2021, without surcharges and penalties, made no later than December 15, 2022, is a prerequisite for the re-registration of the dissolved taxpayer.

The payment corresponding to debts derived from the Tax must be made at Banco de Costa Rica.

In order to proceed with the payment of the periods 2017 to 2021, a request must be submitted by the partners holding at least fifty-one percent (51%) of the shares, which shall be attested by testimony of the deed indicated in the following article. Said request and testimony must be submitted only by e-mail to

Once the request is received, the General Directorate of Taxation will proceed to include in the system said periods.

Once the debt is included, the payment may be made through Real Time Debit (DTR), in the web page of the banking entity chosen by the interested party, or directly at the window by simply indicating the identification number of the legal entity. The amount to be paid will be, for each period, as detailed below:

The juridical entities that have been dissolved and have settled their outstanding debts by December 15, 2022, may submit a request for the cessation of their dissolution to the National Registry. By doing so, these juridical entities will revert to their previous legal status before dissolution, with retroactive effects.

The request for cessation of dissolution must be made in a public deed, with a statement by the shareholders holding at least 51% of the share capital of the entity. The deed must include the date and number of the Gazette in which the corresponding notice was published.

Failure to pay the debts mentioned in the previous article, or payment made after December 15, 2022, will result in the cancellation of the presentation entry of the document, in accordance with Article 5 of Law No. 9428.

Entities that have advertised their status as “liquidated” are not eligible for reactivation. Therefore, as an act that cannot be registered, the presentation of the document must be canceled. In cases where the entity has a liquidator appointed but is advertised as “dissolved under Law 9024,” the appearance must expressly state that the entity has not been liquidated.

This Resolution came into effect on September 30, 2022, and can be applied until December 15, 2022. Please refer to the official resolution in the following link.