If you are buying, lending to or funding a Costa Rican business that imports goods, its cost base just became less predictable. Since a decree published on 28 August, customs taxes imported vehicles on whichever is higher, the invoice or Hacienda’s own reference value, and September’s import data shows how sharply volumes can react. We write this mainly for business buyers and fund allocators, with a note for local importers.
Key takeaways
- Customs tax on imported vehicles is now set on the higher of the invoice value and Hacienda’s reference value, so the declared price no longer fixes the cost.
- September used-vehicle units fell 85.19% from a year earlier and vehicle import tax collected fell 27.24%, though customs also points to emissions-certificate delays.
- Before buying or funding an import-dependent business, ask how its past margins relied on declared values and how it would hold up on reference values.
What happened
- The rule. Executive Decree 45.920 was published on 28 August 2026. Customs compares the commercial invoice value, including freight and insurance, with Hacienda’s reference value for an identical vehicle and taxes the higher one (Delfino). A vehicle missing from the list needs technical information so its value can be set. Individuals who are not registered vehicle sellers may import one vehicle a year.
- Why. Hacienda says a gap opened in mid-September 2024, when three decrees setting minimum import values were repealed and the invoice alone became the base. It identified at least 30,000 vehicles valued well below market and estimates about ₡20,000 million in evaded tax (La Nación, 10 September). The Tico Times converts that to roughly $44 million.
- The September data. La Nación reported on 23 October that 5,019 vehicles came in, 47.7% fewer than a year earlier. Used units were 631, against 3,769 in August, and down 85.19% year on year. Customs value fell to $99.02 million from $123.24 million (down 19.7%), and tax collected was ₡17,697 million, down 27.24%.
- The causes are disputed. Customs says it cannot name a single cause and also cites difficulty obtaining emissions certificates from the transport ministry, which blocked many used units. An association of used-vehicle importers said it would challenge the decree in court; as of the Tico Times report on 26 September it had not filed. Hacienda expects behaviour to correct over time.
Chart: Vehicle import customs value, September 2025 vs September 2026 (US$ million)
| Category | Sep 2025 (US$ m) | Sep 2026 (US$ m) | Change |
|---|---|---|---|
| New vehicles | 105.90 | 93.83 | -11.42% |
| Used vehicles | 17.41 | 5.19 | -70.19% |
| Total | 123.24 | 99.02 | -19.7% |
Why It Matters for Costa Rica
The affected group is wider than car dealers. Any business that imports vehicles for resale, rental fleets or delivery operations now has a landed cost that depends on a government list, not only on the supplier invoice. Customs value is the price base on which import taxes are charged, and under-invoicing (declaring less than the real price) is the practice the decree targets.
The September numbers hint at the mechanism. Units fell 47.7% but customs value fell only 19.7%, which suggests the average declared value per vehicle rose. Tax collected fell 27.24%, less than units but more than value. That is consistent with a higher base per unit and fewer units, though one month cannot separate the rule from seasonality or the emissions-certificate bottleneck.
For lenders and fund managers, the lesson is about margin quality. If a portfolio company earned part of its spread from low declared values, its past margins are not a clean guide to future ones. Used-vehicle importers say their taxes have doubled or tripled; that is the association’s claim, not a verified figure. We did not find authoritative guidance showing this valuation formula applies beyond vehicles, so for any other imported asset ask your Costa Rican attorney or customs broker which valuation rule applies.
Where the Story Is Weaker
One month is thin evidence. Customs itself says it cannot point to one cause, September is typically a slow delivery month for new vehicles according to the importers’ association Aivema (reported by Pravda), and emissions certificates blocked many used units. Sources also differ slightly on timing: the decree was published on 28 August and the Tico Times reports it in effect from 1 September. The court challenge could also change the formula, although we found no sign that it had been filed.
The upside case is that the market adapts. It would need volumes to recover in the coming months while declared values stay near reference values, which would show the rule moved the tax base without freezing trade. Evidence to look for: monthly units recovering, tax per unit holding steady, and no court suspending the decree.
Investor Read-Through
- Business buyers: ask the seller for three years of landed-cost records and how import values were declared; our read, not a forecast, is that margins built on low declared values deserve a haircut.
- Lenders: test an importer’s debt service on a higher tax base and a slower sales cycle, and check inventory in transit under the old rule.
- Fund allocators: ask sponsors whether any portfolio company relied on invoice-based valuation, and how a reference-value base would change cash flow.
- Local importers: check whether each vehicle is on Hacienda’s list and confirm the rule with a customs broker before filing, since no transition period has been announced.
What to watch next: the October vehicle import figures (we have not confirmed a release date; September’s surfaced on 23 October) and whether the importers’ court challenge is filed and whether a court suspends the decree.
Run Your Own Numbers
Take any import-dependent deal and re-price it on the higher of invoice and reference value. A buyer can use it on a target’s landed cost, a lender on debt service, and an allocator on a portfolio company’s gross margin.
| Input | Your assumption | Effect |
|---|---|---|
| Declared invoice value per unit | ||
| Hacienda reference value per unit | ||
| Effective import tax load on the higher value | ||
| Resale price and units sold per month |
Illustration only, not a forecast. Hypothetical: a vehicle is invoiced at $20,000 and Hacienda’s reference value is $35,000. The base becomes $35,000, 75% higher than the invoice. If the effective tax load were about 48%, roughly what the 10 September La Nación example of a luxury SUV implies ($3,540 of tax on a $7,367 declared value), tax would be about $9,600 on the invoice and $16,800 on the reference value, a difference of $7,200. The real rate varies by vehicle.
- Questions to take to a sponsor, advisor or counterparty: how much of last year’s gross margin came from vehicles valued at invoice rather than reference value?
- Which units are in transit or stocked under the old rule, and what is the tax exposure if customs revalues them?
- What happens to covenants and cash flow if the court challenge fails, or succeeds and the rule changes again?
Resumen en español
- Desde el decreto 45.920 (28 de agosto), Aduanas cobra impuestos sobre el mayor entre el valor de factura y el valor de referencia de Hacienda.
- En setiembre ingresaron 5.019 vehículos (47,7 % menos que hace un año); los usados cayeron 85,19 % y la recaudación bajó 27,24 % a ¢17.697 millones, aunque Aduanas también cita demoras en certificados de emisiones.
- Antes de comprar o financiar un importador, revise sus márgenes con el valor de referencia. Próximo dato: las cifras de octubre y si los importadores presentan su recurso judicial.
Related reading: Buying an Export Business in Costa Rica? Read the Trade Gap First; Will Costa Rica Raise Property Taxes?; and our guide to buying a hotel or business. Not sure where to begin? See Start Here. For your own transaction, work with a Costa Rican attorney or notary.
Data as of 24 October 2026. Figures marked preliminary will be revised. This is general market commentary, not investment advice.
Sources
- La Nación: Importación de vehículos se desploma tras cierre de portillo de Hacienda (23 Oct 2026)
- Delfino: Hacienda publica decreto para evitar subfacturación de vehículos (Aug 2026)
- La Nación: Hacienda detecta 30.000 vehículos con valores bajos (10 Sep 2026)
- Tico Times: Costa Rica limits car imports to one per year and taxes them at market value (2 Sep 2026)
- Tico Times: Used-car importers take new vehicle tax formula to court (26 Sep 2026)
- Pravda.Ru: Costa Rica car imports halve after tax loophole closure
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