Declaración Informativa de Precios de Transferencia en Costa Rica

Informative Declaration of Transfer Prices in Costa Rica

Within the framework of the new Resolution on the Informative Declaration of Transfer Prices , the General Directorate of Taxation has established the obligation for certain taxpayers to present an annual informative declaration on transfer prices . This measure seeks to strengthen fiscal control and ensure that transactions with related parties comply with the principle of free competition . 

Obligated Taxpayers 

According to the regulations, the following must submit this annual information declaration: 

  • Companies that carry out operations with related parties , whether national or international. 
  • Companies classified as large national taxpayers or those that operate under the free zone regime . 
  • Companies that have carried out transactions with related parties that exceed the equivalent of 1,000 base salaries in the corresponding fiscal period. 

Relevance of the Declaration 

The presentation of this information allows the Tax Administration to evaluate whether the transactions between related parties have been carried out at market prices and, if not, to make tax adjustments. 

Deadlines and Procedure for Submission 

  • The information declaration must be submitted within three months following the closing of the fiscal period . 
  • For fiscal year 2024 , filing will be made six months after the resolution comes into effect . 
  • The declaration will be made exclusively through the TRIBU-CR platform , eliminating the use of physical formats. 

Penalties for Non-Compliance 

Failure to file within the deadline or including incorrect information could result in: 

  • Financial penalties as established in the Tax Code . 
  • Administrative procedures and tax adjustments by the Tax Administration. 

Recommendations 

To ensure compliance with this new provision, it is recommended: 

  • Prepare in advance : Identify the operations subject to this obligation and gather the necessary documentation. 
  • Familiarize yourself with the TRIBU-CR system : Access it and learn how it works well in advance. 
  • Seek advice from experts : Correct application of transfer pricing principles can avoid tax adjustments and penalties.
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