Costa Rica: Draft Resolution on New Annual Transfer Pricing Disclosure Form

On June 6th, 2016, the Costa Rican tax authority (DGT) introduced a draft resolution requiring an annual transfer pricing disclosure form and set the deadline for its submission by the last business day of June of 2017.

  Taxpayers Subject to New Rules

The requirement applies to taxpayers engaged in domestic or cross-border related party transactions classified as “major national taxpayers,” “large territorial enterprises,” or operating under the “free trade zone agreement” established by Law 7210 of November 23, 1990 and its amendments.



The first annual transfer pricing disclosure form for fiscal year 2015 should be submitted electronically by June 30, 2017.



The scope of the disclosure form includes:

  • listing of inter-company transactions, related parties involved, and selected transfer pricing methods (included in Sections A and B);
  • details of transactions involving tangible assets (included in Section C);
  • details of transactions involving intangible assets (included in Section D);
  • details of financial transactions (included in Section E); and
  • details of service transactions (included in Section F).


It is important to note that the information included in the disclosure form must be consistent with that of the taxpayer’s transfer pricing study.




Failure to submit the disclosure form carries a penalty of 2% of the taxpayer’s previous year gross income.  There is a minimum penalty of 10 base salaries and a maximum of 100 base salaries (2016 base salary equals CRC 424,200 or approximately USD 790).


Errors in the information contained in the disclosure form generate a penalty of one percent (1%) of a base salary for each incorrect item in the disclosure form.


OECD Member Process

Costa Rica is in the process of becoming a member of the OECD and has hosted a regional meeting on BEPS for Latin America and the Caribbean. The new Transfer pricing disclosure form comes three years after the initial introduction of transfer pricing rules in Costa Rica’s tax legislation.  The disclosure initiative stems from Costa Rica’s process of joining the OECD as well as its efforts of establishing itself as a Latin American business center.


BaseFirma has been active in Costa Rica since 2006 and has a group of experts that can assist your company to comply with this new requirement.

For additional information please contact us at:


BaseFirma Inc.

801 Brickell Avenue, Suite 900

Miami, FL 33131


Tel: +1 (305) 461 3212

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