May 28, 2025
Update April 2025
At the beginning of 2025, a major reform to the Free Trade Zone Regime Law (Executive Decree No. 44570-COMEX-H) came into effect. The main changes include:
Streamlining procedures and digitalization : Electronic processing is enabled to authorize companies as auxiliaries to the customs public service, facilitating the issuance of location codes and the resolution of extensions in short periods of time (3 business days).
Facilities for subcontracting and production chains : The management of equipment between subcontracted companies is made more flexible, allowing them to remain outside the main premises for extended periods and eliminating the requirement for temporary return.
Adaptation to teleworking : The use of exempt assets (such as computer equipment) outside the main establishment is authorized, provided that their location and destination are controlled.
Legal certainty in closures or transfers : Processes for disengagement from the regime are strengthened, ensuring that there are no outstanding customs obligations. Documentation for transfers of goods between users of the regime is also clarified.
According to the Ministry of Foreign Trade (COMEX) and PROCOMER , the goal of the reform is to “eliminate unnecessary bottlenecks without weakening controls,” in a joint effort with the Treasury and the private sector .
The OECD's warning: assess sustainability without losing competitiveness
In its Economic Survey 2025 , the OECD recognizes that the Free Trade Zone Regime has been instrumental in:
Diversify the Costa Rican economy.
Increase productivity.
Attract foreign investment.
In 2024, the regime accounted for over 64% of FDI and led exports, particularly in the medical device sector.
However, the OECD also warns that the tax exemptions associated with the regime represent approximately 1.5% of annual GDP in tax expenditure . Therefore, it recommends:
Conduct periodic cost-benefit assessments , especially with regard to the impact on employment, reinvestment and productive linkages.
Align the regime with international standards , such as global minimum tax rules, to avoid regulatory conflicts in tax competition.
In contrast to other tax exemptions (such as VAT on health/education or exempt income from cooperatives ), the OECD has a cautious assessment of free trade zones and highlights their net positive effect on the economy .
Summary table: main reforms to the Free Trade Zone Regulations
Affected area | Major change | Expected impact |
Customs processing | Customs civil service assistant permits are now 100% electronic. | Less time and greater traceability in processes |
Physical expansions | New areas can be activated in a maximum of three business days; faster relocations | Ease of growth without re-processing codes |
Subcontracting and logistics | Allows for maintaining machinery in subcontracted facilities with greater flexibility | Promotes linkages and reduces logistics costs |
Goods in teleworking | Authorized use outside the main enclosure with location control | Adaptation to modern work realities |
Transfers between ZF companies | Differentiated procedures depending on the origin of the asset (imported or local) | Less paperwork; certainty in transactions between users |
Closure or exit from the regime | Mandatory tax review before disengagement | Legal security and control upon exit from the regime |
Final reflection
The discussion in April 2025 reflects a double reality :
On the one hand, Costa Rica needs to maintain an attractive, agile, and modern system to compete globally.
On the other hand, it must prevent tax benefits from eroding the tax base without a clear economic return.
The regulatory reforms are in the right direction , improving operations without compromising oversight. However, as the OECD warns, it will be crucial for the country to strengthen impact measurement mechanisms and adjust the regime when necessary to preserve its legitimacy and effectiveness over the long term .