Métodos de Precios de Transferencia y su aplicación

Transfer Pricing Methods and their application

General Directorate of Taxation - Costa Rica 

In compliance with the new resolution of the transfer pricing information declaration , taxpayers required to file the declaration must apply standardized methods to ensure that their transactions with related parties comply with the principle of free competition . 

Transfer Pricing Methods 

The following methods have been established by the Tax Administration for the valuation of transactions between related parties: 

Comparable Uncontrolled Price (PC) 

  • Compares the price of the transaction between related parties with the price in similar transactions carried out between independent parties. 

Added Cost (AC) 

  • Determine the price of the transaction by adding a profit margin to the cost incurred in the transaction. 

Resale Price (RP) 

  • Calculate the transfer price based on the resale price of a good or service, subtracting an appropriate profit margin. 

Profit Sharing (PU) 

  • It distributes profits among the related parties according to the economic contribution of each one in the generation of value. 

Net Transaction Margin (NTM) 

  • Evaluates the profitability of the transaction based on the results obtained by comparable entities in similar circumstances. 

Valuation of Goods with International Quotation 

  • It applies in the case of goods or services that have market prices established in international markets. 

State Regulated Price 

  • For transactions subject to government regulations, the price set by the regulatory entity will be used. 

Selecting the Right Method 

Each taxpayer must select the most appropriate method based on the nature of the transaction and the availability of comparable information. It is essential to document the justification for the choice and its application in the information return. 

Impact on the Informative Declaration 

  • The application of the chosen method must be reflected in the corresponding section of the TRIBU-CR form. 
  • The Tax Administration may request additional documentation to verify compliance with the principle of free competition. 

Recommendations 

  • Analyze each transaction : Determine which of the methods is most appropriate for each operation. 
  • Document the analysis : Maintain reports that support the selection of the method and the application of the arm's length principle. 
  • Consult with experts : Correct application of the methods can prevent tax adjustments and penalties. 
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