Estonian Company Run from Costa Rica: Tax Rules

Some entrepreneurs who live in Costa Rica form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from San José or the Pacific coast. That works, and Costa Rica's tax on profits is built on the source of income: it taxes profit-making activities of Costa Rican source, whoever carries them on and wherever they were founded, and an administrative centre in Costa Rica of a foreign company is a permanent establishment. Estonia and Costa Rica have no tax treaty. This guide sets out these rules with the official text, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Costa Rican tax adviser before you form or buy the company. We read the Income Tax Law (Law 7092) in its current version on SCIJ, the Costa Rican legal information system of the Procuraduría General de la República, and the Estonian Ministry of Finance's list of tax treaties, on 24 October 2026.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Costa Rica: the company side

A tax on profit of Costa Rican source. The tax on profits applies to persons and entities that carry on profit-making activities of Costa Rican source, and income of Costa Rican source is income generated in the national territory from services provided, assets located, capital invested and rights used there, whatever the nationality, domicile or residence of the parties (Income Tax Law, article 1). Some passive income from abroad is taxed only when it is received by a member of a multinational group without adequate economic substance in Costa Rica (article 1, with article 2 bis).
Founding place and board meetings do not decide. Regardless of nationality, domicile, the place where a legal person was constituted or where its board meets, every enterprise carrying on profit-making activities or business in Costa Rica is a taxpayer (article 2).
An administrative centre is a permanent establishment. A permanent establishment is any fixed place of business where a non-domiciled person carries on all or part of its activity, and administrative centres, branches, agencies and offices are named among them (article 2(b)).
Rate. Legal persons pay 30 per cent of taxable income; lower rates apply to legal persons whose gross income stays below a threshold the law sets (article 15).

An Estonian OÜ is not a Costa Rican company. If you live in Costa Rica and run the business from there, Costa Rica can treat that administrative centre as a permanent establishment of the Estonian company and tax its profit of Costa Rican source. Your Costa Rican tax adviser answers that with the facts of your case.

In Costa Rica: the owner side

Individuals. Individuals domiciled in Costa Rica are taxpayers of the tax on profits for their profit-making activities in Costa Rica, whatever their nationality (article 2(e)).
The owner's other income. How an individual living in Costa Rica is taxed on dividends or other income from a foreign company is governed by other parts of the law, which this guide does not cover. Ask your Costa Rican tax adviser.

No tax treaty between Estonia and Costa Rica

No treaty. Costa Rica is not on the Estonian Ministry of Finance's list of tax treaties in force, signed or initialled.
What that means. There is no treaty rule on a permanent establishment or on the tax on dividends and board fees — each country applies its own law. See board member fee or dividend from abroad for the Estonian side.

What to decide before you form or buy the company

Where the business is run. An administrative centre in Costa Rica is a permanent establishment.
Where the income comes from. Services provided and capital invested in Costa Rica give income of Costa Rican source.
How profits reach you. Without a treaty, each country applies its own rules to dividends and board fees.

The two company forms side by side — founding document, capital, share transfer and the company tax: Estonian OÜ or Costa Rican S.R.L..

What we do on the Estonian side

for your own company, a written analysis of its tax residence and permanent establishment under these rules — an analysis, not tax advice;
online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Costa Rican tax returns and Costa Rican tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Costa Rican tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Costa Rica if I run it from Costa Rica?

It can be. Costa Rica taxes profit-making activities of Costa Rican source (Income Tax Law 7092, article 1), and every enterprise carrying on such activities in Costa Rica is a taxpayer, whatever the place where it was constituted or where its board meets (article 2). An administrative centre in Costa Rica of a foreign company is a permanent establishment (article 2(b)); legal persons pay 30 per cent (article 15). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Estonia and Costa Rica have no tax treaty, so each country applies its own law. Ask a Costa Rican tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Costa Rica: what is taxed where