Central America and the Caribbean: Legislative, administrative, and judicial tax developments (August 2026)

The KPMG member firm in Costa Rica has prepared an August 2026 report (English and Spanish) that provides summaries of recent tax, regulatory, and court developments affecting taxpayers across the region.

Costa Rica

• The General Directorate of Taxation published proposed amendments to corporate income tax return forms and VAT return forms that would require certain returns filed through TRIBU-CR to identify the accounting or economics professional responsible for their preparation. For corporate income tax purposes, the requirement would apply to returns for fiscal year 2026; for VAT purposes, it would apply to self-assessed returns filed after the resolution takes effect. The requirements would not apply to amended returns for prior periods.
• The General Directorate of Taxation concluded that commissions paid to a nonresident digital platform for accommodation booking intermediation services constitute Costa Rican-source income subject to the withholding tax on remittances abroad at a 30% rate under the residual category of Article 59(l) of the Income Tax Law, rather than the 15% rate applicable to certain commissions under Article 59(i).

Guatemala

• Decree No. 18-2026 amended the single tax on real estate (IUSI), including changes to taxable value thresholds; a 0% rate for qualifying housing, residential, or mixed-use properties; and an income tax exemption for capital gains earned by individuals in certain real estate transactions.
• Decree No. 19-2026 extended the deadline for payment of the motor vehicle circulation tax until the last business day of December 2026 and provided relief from penalties, late-payment surcharges, and interest for taxpayers satisfying the applicable conditions.

Panama

• Executive Decree No. 32 implemented the economic substance requirements under Law No. 526 of 2026 for certain foreign-source passive income earned by entities belonging to multinational groups. The regulations address economic substance criteria, outsourcing of core activities, documentation and record retention, foreign tax credits, and income from intangible assets.
• Law No. 546 of 2026 amended the real property transfer tax (ITBI) regime for the first sale of new residential properties, including an exemption for the first B/.120,000 of the taxable base and a preferential rate scale for qualifying properties with a taxable base exceeding B/.120,000 but not exceeding B/.200,000.
• The Directorate General of Revenue (DGI) issued Resolution No. 201-6989, extending until September 30, 2026, the deadline for filing Form 930 (transfer pricing report) for tax year 2026 for taxpayers maintaining a special fiscal period, following technical issues with the e-Tax 2.0 system.
• The Tax Administrative Court held that filing a motion for reconsideration does not suspend the statute of limitations for tax collection when the Tax Code does not provide for such an effect, and found that the seven-year limitation period had expired with respect to income tax assessed under the alternative calculation of income tax (CAIR) method for tax year 2014.

Dominican Republic

• The General Agency for Internal Taxes (DGII) announced an extension of temporary FATCA relief for financial institutions unable to obtain U.S. taxpayer identification numbers for certain reportable U.S. accounts for the 2025, 2026, and 2027 reporting periods. Financial institutions must satisfy specified requirements, including annually requesting missing U.S. TINs and reporting applicable IRS explanation codes.
• The DGII announced that taxpayers classified as “large local and medium-sized taxpayers” must exclusively issue electronic tax receipts using type “E” sequences beginning November 1, 2026, with type “B” non-electronic sequences remaining valid only through October 31, 2026.
• The Administrative Superior Court held that the Dominican Customs Authority must provide an individualized justification for the sequential rejection of customs valuation methods when reassessing import declarations, and annulled a challenged resolution that failed to adequately explain the valuation methods applied.
• The Administrative Superior Court held that evidence showing transmission of a communication through the tax authority’s Virtual Office is insufficient by itself to establish actual receipt for purposes of suspending the statute of limitations. The court also held that a late-filed tax return interrupts the limitation period as an acknowledgment of the tax liability but does not trigger the additional two-year suspension applicable to a failure to file.
• The Administrative Superior Court held that the DGII must establish compliance with each stage of the administrative penalty procedure to sustain a tax penalty, and revoked a penalty when the DGII failed to provide the infringement report, proof of notification, and other documentation supporting the sanctioning procedure.
• The Administrative Superior Court held that the DGII may not assess and collect tax arising from a period that was not included in the tax audit formally notified to the taxpayer, and ordered the exclusion of ITBIS adjustments for October 2021 from an audit covering December 2020 and April 2021.