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Introduction of a QDMTT into the Costa Rican Special Tax Regime

Brenes, Rolando Jose LU (2025) HARN60 20251
Department of Business Law
Abstract
This thesis examines the potential constitutional restrictions that may prevent Costa Rica from introducing a Qualified Domestic Minimum Top-Up Tax (QDMTT) into its legislation, specifically targeting in-scope Constituent Entities operating under the country’s Special Tax Regime. The main research question explores whether the constitutional principles of non-retroactivity and legitimate expectations could restrict the possibility of introducing such a measure. Through a doctrinal legal approach of the national constitutional provisions and binding case-law, the research finds that applying a QDMTT to entities already operating under the Special Regime would infringe constitutionally protected principles, and would likely be deemed... (More)
This thesis examines the potential constitutional restrictions that may prevent Costa Rica from introducing a Qualified Domestic Minimum Top-Up Tax (QDMTT) into its legislation, specifically targeting in-scope Constituent Entities operating under the country’s Special Tax Regime. The main research question explores whether the constitutional principles of non-retroactivity and legitimate expectations could restrict the possibility of introducing such a measure. Through a doctrinal legal approach of the national constitutional provisions and binding case-law, the research finds that applying a QDMTT to entities already operating under the Special Regime would infringe constitutionally protected principles, and would likely be deemed unconstitutional. (Less)
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author
Brenes, Rolando Jose LU
supervisor
organization
course
HARN60 20251
year
type
H1 - Master's Degree (One Year)
subject
keywords
Qualified Domestic Top-Up Tax, Non-retroactivity, Legitimate Expectations, Special Tax Regime, Costa Rica.
language
English
id
9195008
date added to LUP
2025-06-09 09:58:43
date last changed
2025-06-09 09:58:43
@misc{9195008,
  abstract     = {{This thesis examines the potential constitutional restrictions that may prevent Costa Rica from introducing a Qualified Domestic Minimum Top-Up Tax (QDMTT) into its legislation, specifically targeting in-scope Constituent Entities operating under the country’s Special Tax Regime. The main research question explores whether the constitutional principles of non-retroactivity and legitimate expectations could restrict the possibility of introducing such a measure. Through a doctrinal legal approach of the national constitutional provisions and binding case-law, the research finds that applying a QDMTT to entities already operating under the Special Regime would infringe constitutionally protected principles, and would likely be deemed unconstitutional.}},
  author       = {{Brenes, Rolando Jose}},
  language     = {{eng}},
  note         = {{Student Paper}},
  title        = {{Introduction of a QDMTT into the Costa Rican Special Tax Regime}},
  year         = {{2025}},
}