Countries › Costa Rica › Guide › 6. Taxes › Tax audits and disputes in Costa Rica: four year review period, 50% to 100% penalties with voluntary reductions, appeals to the Tribunal Fiscal Administrativo

Tax audits and disputes in Costa Rica: four year review period, 50% to 100% penalties with voluntary reductions, appeals to the Tribunal Fiscal Administrativo

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Last verified: 2026-10-29 · Status: Stable

The tax administration has four years to assess and collect, ten years for unregistered taxpayers, fraudulent returns or returns not filed. Understatements are penalised at 50% of the tax shortfall, 100% where data was concealed, with reductions of up to 80% for voluntary correction before any audit, and late payment carries interest. Taxpayers can contest an assessment through an optional reconsideration within 30 business days and then appeal to the Tribunal Fiscal Administrativo within 30 days; written rulings must be answered in 45 days.

USD figures use the Banco Central de Costa Rica reference selling rate of ₡454.82 per US dollar published for 29 October 2026 (indicator 318 on bccr.fi.cr), rounded to the cent. The salario base for 2026 is ₡462,200 (Circular 246-2025 of the Consejo Superior del Poder Judicial, under Ley 7337 art. 2).

Key facts

Ordinary review period	4 yearsLey 4755 art. 51, as of 2026-10-29 · in force
Extended review period (unregistered, fraudulent or unfiled)	10 yearsLey 4755 art. 51, as of 2026-10-29 · in force
Penalty on tax shortfall	50 %Ley 4755 art. 81, as of 2026-10-29 · in force
Penalty where data was concealed	100 %Ley 4755 art. 81(3)(a), as of 2026-10-29 · in force
Maximum reduction for spontaneous correction with self assessed payment	80 %Ley 4755 art. 88(a), as of 2026-10-29 · in force
Late filing fine (50% of salario base, 2026)	231100 CRCLey 4755 art. 79; Circular 246-2025, as of 2026-01-01 · in force
Appeal to the Tribunal Fiscal Administrativo	30 daysLey 4755 art. 156, as of 2026-10-29 · in force
Deadline to answer a ruling request	45 daysLey 4755 art. 119, as of 2026-10-29 · in force
Tax fraud criminal threshold (500 salarios base, 2026)	231100000 CRCLey 4755 art. 92; Circular 246-2025, as of 2026-01-01 · in force

The rule

1. The power to assess and to collect tax and interest prescribes in four years, extended to ten years for taxpayers not registered, or registered but with returns classed as fraudulent or not filed, applied tax by tax (art. 51). The term runs from the first day of the month after the tax was due (art. 52) and is interrupted, among others, by notice of an audit (if it starts within a month and is not suspended for more than two months), self assessment, acknowledgment of the debt and payment plans (art. 53).Ley 4755, Código de Normas y Procedimientos Tributarios, art. 51, 52 and 53, 2016-12-14 official text · verified 2026-10-29

2. Late payment accrues interest automatically at a rate set by resolution at least every six months, equal to the average state bank commercial lending rate and no more than ten points above the BCCR basic deposit rate; it cannot be waived except for administrative error (art. 57). Taxes assessed by the administration and paid after 15 days bear a further 1% per month, capped at 20% (art. 80).Ley 4755, art. 57 and art. 80, 2012-09-10 official text · verified 2026-10-29

3. Not filing a return on time is fined 50% of a salario base (art. 79). Omitting returns, filing inaccurate returns or claiming improper refunds is fined 50% of the shortfall, and 100% where data was concealed and the concealed debt exceeds 10% of the base (art. 81).
Cost to do it: Late filing fine in 2026: ₡231,100 (US$508.11).Ley 4755, art. 79 and art. 81, 2012-09-10 official text · verified 2026-10-29

4. Penalties are reduced by 75% (80% if self assessed and paid) for spontaneous correction before any action by the administration; 50% (55%) for correction after the administration acts but before the assessment; and 25% (30%) if the taxpayer accepts the assessed facts within the appeal period (art. 88).Ley 4755, art. 88, 2012-09-10 official text · verified 2026-10-29

5. After an audit the administration proposes a regularisation; if not accepted, it issues charges, which the taxpayer may pay under protest without accepting them (art. 144). Against the assessment an optional reconsideration (revocatoria) may be filed within 30 business days, to be decided in 30 business days (art. 145); then, or directly, an appeal lies to the Tribunal Fiscal Administrativo within 30 days of notice (art. 146 and 156).Ley 4755, art. 144, 145, 146 and 156, 2012-09-10 official text · verified 2026-10-29

6. A taxpayer may submit a written ruling request on a concrete current situation; the administration has 45 days, after which the taxpayer's stated interpretation is deemed approved for that case. A request filed before the return deadline protects against penalties if the resulting difference is paid within 30 days (art. 119).Ley 4755, art. 119, 2012-09-10 official text · verified 2026-10-29

7. Tax fraud exceeding 500 salarios base per period is a crime punished with five to ten years in prison; voluntary correction before any administrative action is a legal excuse (art. 92).
Cost to do it: Threshold in 2026: ₡231,100,000 (US$508,113.10).Ley 4755, art. 92, 2016-12-14 official text · verified 2026-10-29

Worked example

An audit finds ₡20,000,000 (US$43,973.44) of unpaid income tax with no concealment. The penalty is 50%, ₡10,000,000; if the company accepts the facts and pays before the assessment is issued, self assessing the fine, it falls by 55% to ₡4,500,000 (US$9,894.02), plus interest.

Step by step

Keep books and support for at least the four year period, longer for carried forward items such as disallowed interest.
On notice of an audit, assess exposure early: reductions shrink at each stage.
Consider paying under protest to stop interest while contesting.
File the revocatoria within 30 business days or appeal to the Tribunal Fiscal Administrativo within 30 days.

Common traps

Not filing a return extends the review period to ten years (art. 51).
Interest is never waived except for administrative error (art. 57).
Audit notices interrupt prescription and the term restarts on 1 January of the following year (art. 53).

Sources

Related: Costa Rica country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

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