Taxpayers operating in Costa Rica may be required to file the Transfer Pricing Informative Return (Form 273) before the Costa Rican Taxing Authority, the Dirección General de Tributación (DGT) if certain conditions are met.
The following taxpayers will need to file the Transfer Pricing Informative Return:
- Taxpayers classified as National Large Taxpayers that carry out domestic or cross-border transactions with related parties.
- Taxpayers operating under the Free Trade Zone Regime that carry out domestic or cross-border transactions with related parties.
- Taxpayers that carry out domestic or cross-border transactions with related parties exceeding the equivalent of 1,000 base salaries (₡462,200,000 or roughly USD 970,600), whether considered individually or in aggregate.
Key deadlines:
- Fiscal year 2024 – Filing deadline: March 31, 2026
- Fiscal year 2025 – Filing deadline: June 30, 2026
For subsequent fiscal years, the Transfer Pricing Informative Return will need to be filed within six months after the taxpayer’s fiscal year-end (e.g., 30 June for calendar year taxpayers).
Potential Penalties:
Failure to comply with the filing requirement may result in monetary penalties. Under the current regulations, fines may range from three to one hundred base salaries, which currently represents approximately ₡1,386,600 to ₡46,220,000 (approximately USD 2,910 to USD 97,100), depending on the severity of the non-compliance.
Additional Considerations:
Taxpayers engaged in related-party transactions must also prepare an annual Transfer Pricing report, which must be kept available in the event of an audit. The Transfer Pricing report must properly support the information disclosed in the Transfer Pricing Informative Return.
Given the increasing focus of the Costa Rican Tax Authority on transfer pricing compliance, it is essential for multinational groups operating in Costa Rica to review their obligations in advance and ensure their documentation is aligned with local requirements.
Early preparation can make the difference between a smooth filing process and potential exposure to penalties.
For any questions or comments, reach out to your local BaseFirma contact:
Solange Martinez – solange.martinez@basefirma.com
Eduardo Emmerich – eduardo.emmerich@basefirma.com
#TransferPricing #CostaRica #TaxCompliance #Form273 #BaseFirma