Costa Rica VAT Contingency Measures Update 2025

On December 5, 2025, the Costa Rican General Directorate of Taxation (GDT) published a Resolution titled “Authority to Minimize Potential Accounting Impact Caused by the Application of the Contingency Measure”, addressing unintended accounting and tax effects arising from the temporary contingency measures previously introduced. 

More specifically, the Resolution follows the October 2025 GDTs statement, which established contingency rules for taxable persons who reported purchases in September but did not register any sales during the same period.

The Resolutions Objective

The previously established measures were designed to flag or control inconsistencies in VAT reporting. However, in practice, they risked generating distortions in accounting records, such as artificial tax balances or mismatches between input and output tax positions. The DTG recognized these issues and, in its December Resolution, formally granted the power to mitigate or adjust the accounting impact of the application of those contingency measures.

The DTG acknowledges that the automatic application of the October controls could produce effects that do not reflect the taxable person’s real economic activity. Thus, with new measures in place, the authority allows corrective actions to avoid disproportionate or technically incorrect outcomes. The primary purpose is not to create a tax benefit, but to correct technical effects generated by a temporary compliance workaround.

In practical terms, taxable persons who, in the September 2025 VAT period, had no taxable sales but did incur taxable purchases and therefore applied the contingency measure by declaring one Costa Rican Colón (CRC) of taxable sales in Form 150 are expressly authorized to correct that declaration in later periods.

Conclusion

The Resolution functions as a safeguard, aiming to preserve the neutrality of the tax system and prevent temporary compliance mechanisms from creating lasting accounting or fiscal distortions for affected taxable persons. More specifically, the December Resolution ensures that the temporary reporting measure does not permanently affect sales figures or distort the taxable persons’ accounting and VAT position.

Source: KPMG