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V2343-25 3 December 2025 · SG de Fiscalidad Internacional Criterion in force
IRNR · pensión de jubilación privada

Spanish private pensions paid to Costa Rican residents are only taxed in Costa Rica

A Spanish citizen moving to Costa Rica asks how his private pension will be taxed. The DGT states that, under the Spain-Costa Rica double taxation treaty, such a pension is only subject to taxation in the country of residence.

The DGT's ruling

As it concerns a private retirement pension, Article 18 of the Convention between Spain and Costa Rica applies. This article, which has not been modified by the MLI, establishes that pensions paid by reason of former employment may only be taxed in the State where the beneficiary is a resident. Therefore, as the individual is a resident in Costa Rica, the pension is only taxed in said country.

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