The General Directorate of Taxation has officially published Resolution MH-DGT-RES-0026-2025, which sets forth the general provisions for submitting the Transfer Pricing Informative Return (TP IR). This regulation aims to enhance tax control over related-party transactions, ensuring they are valued according to the Arm’s Length Principle.
Taxpayers required to file this return include:
- Large National Taxpayers engaged in domestic or cross-border transactions with related parties.
- Free Trade Zone Regime Entities conducting operations with related parties.
- Income Taxpayers whose transactions, individually or collectively, exceed 1,000 base salaries (around USD 900.000) during the relevant fiscal period.
The TP IR must be submitted via the TRIBU-CR digital platform, within three months after the end of the fiscal period. However, for the 2024 fiscal year, a special deadline of six months from the Resolution’s effective date applies, that is on November 30, 2025.
The regulation also outlines penalties for non-compliance, including administrative procedures for failure to file the Return on time.
This resolution repeals previous provisions (DGT-R-44-2016 and DGT-R-28-2017) and represents a major step forward in modernizing Costa Rica’s tax system, aligned with the Digital Treasury for the Bicentennial initiative.
As Transfer Pricing specialists, we are available to support you with this new requirement and any other related inquiries in the region.