Three significant amendments impacting the fiscal and operational landscape in Nicaragua were published in La Gaceta, the Official Gazette on April 9, 2026. Taken together, these changes reflect a dual trend: enhanced investment incentives alongside a more structured compliance and control framework:
- Law No. 1278, Amendments and Additions to Law No. 917, Free Zones Law.
- Law No. 1279, Amendments and Repeal of Law No. 822, Tax Concertation Law.
- Law No. 1280, Addition to Law No. 265, Customs Self-Dispatch Law for Imports, Exports, and Other Regimes.
Amendment to the Free Zones Law (Law No. 917)
The amendment significantly expands the tax incentives available under the regime, including:
- The possibility of successive extensions of benefits for 15-year periods, subject to authorization.
- The express inclusion of a dividend tax exemption applicable to operators, users, and their shareholders.
- For user companies: a transition from full exemption to a 60% exemption starting in year 11, with the possibility of further extensions.
- Indefinite exemptions from municipal taxes.
These changes enhance the predictability of the regime by removing prior limitations and enabling more robust long-term planning. Notably, the extension of benefits to dividends broadens the incentive beyond operational income to profit distribution.
Companies should consider reevaluating their corporate structures and profit repatriation strategies, assessing eligibility to enter or remain within the regime, and preparing for extension requests while ensuring compliance with applicable regulatory conditions.
Amendment to the Customs Self-Dispatch Law (Law No. 265)
A new requirement has been introduced in the context of foreign trade:
- The obligation to submit a declaration confirming the absence of forced labor in the production of imported godos.
- The authority of the General Directorate of Customs Services (DGA) to request additional documentation and conduct verifications.
This change shifts the focus from traditional customs compliance to a supply chain due diligence model. It is no longer sufficient to declare compliance; companies must now substantiate the ethical origin of goods.
In this context, companies are encouraged to strengthen internal processes by implementing due diligence mechanisms for international suppliers, thereby enhancing visibility and control over their supply chains. Supporting documentation, such as certifications and traceability records, will be key, as will updating commercial agreements to include clauses aligned with international labor standards.
Amendment to the Tax Concertation Law (Law No. 822)
The amendment introduces changes to the tax base and the recognition of tax credits, with a particular focus on specific industries. Key aspects include:
- A shift in the taxable base from the “retail” level to the “distributor” level for local sales.
- The application of customs value as the tax base for imports.
- Recognition of tax credits for the importation and local sale of certain products.
- Elimination of the Selective Consumption Tax (ISC) on certain goods (such as fruits and turkey).
The reform primarily impacts sectors such as alcoholic beverages, beer, tobacco products, and non-alcoholic beverages, including juices, soft drinks, and energy drinks, where changes to the taxable base and tax credit recognition will directly affect operations.
From a business perspective, these changes may require adjustments to cost structures, pricing strategies, and the overall effective tax burden across the distribution chain. Companies are advised to review pricing models and margins, adapt accounting and tax systems to the new determination criteria, and ensure proper application of available tax credits.
More opportunities and a stronger compliance framework
These amendments should be analyzed holistically, as together they shape a new operating environment. On one hand, the free zones regime expands incentives and opens new investment opportunities; on the other, foreign trade provisions raise compliance and traceability standards, while domestic tax changes adjust both tax burdens and calculation criteria.
In this context, companies will operate in an environment with greater opportunities, supported by a more structured and technical regulatory framework.
Businesses already operating in the country, as well as those considering investment, should evaluate the tax, operational, and contractual implications of these changes. At the same time, they should update internal structures and processes, strengthen compliance and documentation mechanisms, and align their tax strategies accordingly.
