Aspectos Claves Declaración Informativa de Precios de Transferencia en Costa Rica

Key Aspects of the Transfer Pricing Information Statement in Costa Rica

The General Directorate of Taxation has published , for public consultation, the guideline that establishes the obligation to submit an annual information declaration on transfer pricing. This measure seeks to guarantee compliance with the principle of free competition in transactions between related parties and to strengthen fiscal control in the country.  

Obligated Subjects The obligation to submit this declaration falls on: 

  • Taxpayers of the income tax who carry out transactions with related parties , both within and outside the national territory. 
  • Large national taxpayers or companies under the free zone regime . 
  • Companies whose transactions with related parties exceed 1,000 base salaries in the corresponding fiscal period. 

Submission Deadlines 

  • The information declaration must be submitted within three months following the closing of the authorized fiscal period . 
  • For the 2024 fiscal period, the declaration must be submitted six months after the resolution comes into force . 

New TRIBU-CR System 

  • The presentation of the informative declaration will be carried out in a mandatory manner through the TRIBU-CR system . 
  • Declarations will not be accepted in physical format or by other means. 

Contents of the Declaration 

  • General taxpayer information. 
  • Data from associated companies. 
  • Details of transactions carried out with related parties (tangible assets, intangible assets, financial transactions, services). 
  • Transfer pricing methods used and profitability analysis. 

Penalties for Non-Compliance 

  • Failure to submit the declaration or omission of relevant information may result in tax adjustments, economic sanctions and administrative procedures by the Tax Administration. 

Recommendations for Taxpayers 

Prepare ahead of time : Gather the required information with enough time to avoid errors or inconsistencies. 

Familiarize yourself with the TRIBU-CR system : Access the platform and understand how it works to ensure a successful submission. 

Seek advice from experts : Correct application of transfer pricing methods and financial analysis can be key to avoiding tax adjustments. 

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