Costa Rica: Tax Authority issues transfer pricing guidelines

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Costa Rican tax authority on 21 April 2017, issued Resolution DGT-R-16-2017 in relation to transfer pricing documentation guidelines. The Resolution establishes requirement of taxpayers having transactions with related parties to retain supporting documentation of certain corporate information and company local information.  The requirements are aligned with Master File and Local File maintenance as proposed by the OECD BEPS project.

The DGT’s corporate information is equivalent to the Master File that is summarizes qualitative and quantitative data from the multinational group. The company local information (equivalent to the Local File) requires the taxpayer to provide the organization structure, chain value, financial information etc. Failure to comply with this provision could lead to a penalty of an amount up to approximately USD 90,000.

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