Absence of a France-Costa Rica tax treaty: French law and exchange of information

France does not have a tax treaty in force with Costa Rica: the country does not appear in the official BOFiP (Official Bulletin of Public Finances). The instrument that the French tax authorities mention for this country is an information exchange agreement, which entered into force on December 14, 2011. For a French tax resident, income from Costa Rican sources remains taxable in France, and the instructions for form 2047 indicate that income from securities originating in Costa Rica does not qualify for a tax credit. This page details these rules and the declaration of accounts. It does not provide any Costa Rican tax rates: the text of the Costa Rican income tax law could not be obtained from the official source.

Costa Rica missing from BOFiP list

Appendix BOI-ANNX-000306 of the BOFiP (French Official Tax Bulletin), "List of tax treaties concluded by France," has been in effect since April 29, 2026. It only lists agreements and conventions in force on January 1, 2026. Among the South American, Central American, and Mexican states, it includes Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Mexico, Panama, and Venezuela, as well as Jamaica and Trinidad and Tobago for the Caribbean. Costa Rica is not included. A signed agreement that had not yet entered into force by that date would not be visible in this list.

Costa Rican income of a French tax resident

French tax residence is determined according to Article 4 B of the French General Tax Code (CGI). The Official Bulletin of Public Finances (BOFiP) identifies three criteria: the home or principal residence, professional activity (whether salaried or not), and the center of economic interests. Only one of these criteria is required. A stay of more than six months is not an absolute criterion.

When the taxpayer's residence is in France, the practical guide to income tax states the rule for foreign-sourced income: "In the absence of a tax treaty, the income is taxable in France." The instructions for form 2047 (for income tax return filed in 2025) add that, for securities and investments, income originating in a country without a tax treaty with France does not qualify for a tax credit. This income is declared net of any tax withheld abroad. If no tax was withheld locally, the gross amount is shown on form 2047.

The deductions made in Costa Rica are not detailed here: the sources consulted do not provide a legal rate.

The information exchange agreement of 14/12/2011

The annex to the draft finance bill concerning France's intelligence-sharing network contains a table of states that have concluded an administrative assistance agreement with France. The version read is in force as of September 1, 2026. The entry for Costa Rica reads "Intelligence exchange agreement entered into force on December 14, 2011," followed by a cross.

This line states only one thing: an information exchange agreement exists between the two states. The page makes no claim that this agreement affects income taxation, and it draws no conclusions from the cross: its exact value has not been verified in the PDF.

The same document indicates that the French list of non-cooperative states and territories includes 11 names since the decree of April 15, 2026: Anguilla, Antigua and Barbuda, Guam, the U.S. Virgin Islands, the Turks and Caicos Islands, Palau, Panama, Russia, American Samoa, Vanuatu, and Vietnam. Costa Rica is not on the list.

Costa Rica's draft common standard for reporting

The Costa Rican Ministry of Finance (Hacienda) published a draft resolution from the Directorate General of Taxation on due diligence for the automatic exchange of financial information (CRS standard), open for public consultation from October 6 to 19, 2026. The consultation period ended on the date of this page review: as of October 19, 2026, the Hacienda website lists this draft under the heading "Procesos de consulta pública finalizados" (Public Consultation Processes Finalized). It is a draft: the resolution number and date are left blank.

According to the document under review, the project contains the following:

• It is addressed to Costa Rican financial institutions required to report (article 1).
• The declaration must be submitted no later than July 31 of the year following the year to which the information relates (Article 8.1).
• Pre-existing accounts are defined by reference to December 31, 2016 (article 2).
• Recital III indicates that Costa Rica acceded to the OECD Convention on Mutual Administrative Assistance in Tax Matters by Law 9118 of February 7, 2013.

The page draws no conclusions about the exchanges with France: the project is not in force, and the French list read does not bring this text closer to the Costa Rica line.

Bank account in Costa Rica for a French resident: typical case (fictitious profile)

Situation. Marc, a fictitious profile, is a tax resident of France. He opens an account in a Costa Rican bank and receives interest payments there.

Issue. He wants to know what he needs to declare in France and how these interests are treated.

Strategy. He first checks that France does not have a tax treaty with Costa Rica, using the BOFiP list. He attaches form 3916 to his income tax return for the account. He reports the interest on form 2047, for the net amount of any tax withheld locally, without claiming a tax credit.

Result. Marc fulfills two separate obligations: the account must be declared using form 3916, and the interest earned must be declared using form 2047. Failure to file form 3916 results in a fine of €1,500 per undeclared account, according to the tax authorities' website. This website stipulates a fine of €10,000 for an account located in a country that has not signed a tax treaty: its applicability to Costa Rica is not established here. No tax figures are calculated due to the lack of a confirmed Costa Rican tax rate.

French income of a resident of Costa Rica

A non-resident is taxed only on their French-source income, subject to tax treaties. The minimum rate is 20% of income up to €29,579 and 30% of income above that amount, for income received in 2025. Dividends from French sources paid to a non-resident are subject to a withholding tax of 12.80% (rate in effect as of January 1, 2026), subject to more favorable provisions under tax treaties. Since no treaties are listed for Costa Rica, no treaty reductions are discussed here.

What changes depending on your situation

• Your tax residence: France, Costa Rica, or a shared situation.
• The nature of the income: interest, dividends, capital gains, rents.
• Details of the deductions made on site should be confirmed by a Costa Rican professional.
• Accounts and contracts held in Costa Rica must be declared in France.
• The date of your transactions in relation to the possible entry into force of the draft common reporting standard.

The rule depends on your situation. No results are guaranteed.

What this page does not cover

It does not provide information on Costa Rican income tax rates, the criteria for Costa Rican tax residency, wealth tax, social security contributions, or residency permits. It also does not address dual residency: the BOFiP (French Official Tax Bulletin) on the allocation of residencies describes the order stipulated by tax treaties and does not cover cases without a treaty. Local tax matters should be verified with a Costa Rican tax professional; French tax matters are addressed in our sections on tax domicile, the 2047 tax return, and form 3916.