Today, February 26, 2025, is the final deadline for submitting public comments on Resolution MH-DGT-RES-000-2025, issued by the General Directorate of Taxation. This resolution provides an opportunity for entities representing general, corporate, or diffuse interests to submit their observations on the proposed guidelines for the submission of the Transfer Pricing Informative Return.
According to Resolution MH-DGT-RES-000-2025 and the current regulations in Costa Rica, the following taxpayers are required to submit the Transfer Pricing Informative Return, ensuring that their transactions with related parties are valued in accordance with the Arm’s Length Principle:
- Large National Taxpayers: Entities engaged in domestic or cross-border transactions with related parties.
- Free Trade Zone Regime Entities: Companies conducting operations with related parties.
- Income Taxpayers: Entities whose transactions, either individually or collectively, exceed the equivalent of 1,000 base salaries during the relevant period.
The required information must be submitted through the TRIBU-CR Digital Platform.
This Return is due within three months following the end of the fiscal period. However, for the 2024 fiscal period, the Transfer Pricing Informative Return must be filed within six months from the resolution’s entry into force.
The Resolution also specifies penalties for non-compliance. Taxpayers who fail to submit the Return within the stipulated timeframe will be subject to administrative penalties.
As Transfer Pricing specialists, we are available to assist you with this matter and any other inquiries related to Transfer Pricing in the region.