HONDURAS Trends and Developments Contributed by: Alberto Zúniga and Carlos Zúniga, Baker Tilly Honduras
established by Honduran law as a special economic jurisdiction with broad autonomy over certain admin - istrative, regulatory and fiscal matters within its geo - graphic boundaries on the Bay Islands. From a tax perspective, Próspera was designed to offer distinc - tive and investor-friendly tax terms compared with the standard Honduran regime. The concept was to cre - ate a regulatory and fiscal environment with interna - tional-style certainty, aimed at attracting foreign direct investment into sectors such as tourism, services, technology, logistics and specialised manufacturing. The level of autonomy granted under the ZEDE frame - work generated significant domestic debate. Although this is still a matter in dispute, it reinforces the connection between domestic incentive policy and international dispute mechanisms. While the case concerns a specific regulatory framework that can be subjected to debate regarding not just tax policy but also constitutional sovereignty, this case illustrates how modifications to special regimes can extend beyond domestic legislative debate and enter the sphere of treaty-based protection. Together, these developments created a period in which the durability of special regimes was and still is actively questioned. That period now forms the backdrop against which current measures are being evaluated. A new administration, a new adjustment An important structural difference for the upcoming tax outlook is the change in administrative posture under the current government. Political influence aside, early measures under the current administration suggest incremental adjustment rather than compre - hensive reform. These new adjustments are exemplified by Executive Decree 2-2026, which extended the Temporary Import Regime ( Régimen de Importación Temporal – RIT), a customs and tax regime designed for export-orient - ed industries. It permits the temporary importation of raw materials, intermediate goods, machinery and equipment without the payment of customs duties and certain internal taxes, on the condition that the imported inputs are incorporated into goods that are subsequently exported. The regime functions as a
suspension of duties rather than a blanket exemption, and requires compliance with reporting, inventory and export verification procedures. The Temporary Import Regime plays a central role in Honduras’ export model. Industries such as textiles, agro-industrial processing and manufacturing rely heavily on customs suspensions and defined tax relief periods to remain competitive. The extension of this regime therefore preserves a key structural compo - nent of the country’s fiscal architecture. By reinforcing one of Honduras’ principal industrial incentive mechanisms, the tax policy seeks to extend planning visibility for export-oriented industries that rely on customs suspension and related tax benefits. Maintaining this framework signals continuity within the established incentive structure. In another initial reform, Executive Decree No 7-2026 introduced a temporary amnesty programme appli - cable to outstanding municipal, energy, vehicle, tel - ecommunications, water, tax and migration-related obligations. The measure functions primarily as a compliance and liquidity mechanism, allowing taxpay - ers to regularise accumulated liabilities. While it does not alter the corporate tax system, it reflects an effort to stabilise administrative relations while addressing prior enforcement backlogs. In parallel, renewed steps toward re-engagement with the International Centre for Settlement of Investment Disputes (ICSID) contribute to institutional signalling. Participation in recognised international arbitration frameworks may support perceptions of legal stability, particularly following recent dispute exposures involv - ing special regimes. Taken together, these measures indicate a preference for maintaining and managing the existing incentive- based structure rather than redesigning it, signalling how investors in Honduras navigate policy adjust - ments. Determining stability for investments The central issue for investors is whether Honduras can deliver stability after a period in which tax reform proposals, administrative changes and international
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