Costa Rica's Legislative Assembly is considering Bill 23675, which contains amendments to the Income Tax Law to resolve issues that have resulted in the country's listing as a non-cooperative jurisdiction by the EU. This includes amendments regarding its "harmful" foreign source income exemption regime. The main amendments include the introduction of new rules for the taxation of passive income obtained from abroad by non-qualified entities that are part of an economic group, including Costa Rican entities and permanent establishments in Costa Rica. For this purpose, economic substance requirements are introduced for determining whether an entity is qualified or not. When...