On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations.
The new Regulation defines persons as related persons who are resident in jurisdictions with an income tax rate of 18% or less and /or in jurisdictions that do not have tax information exchange agreements with Costa Rica.
Companies required to file transfer pricing return those are operating in a free trade area or classified as “large taxpayers” under the Large Territorial Company (GETES) program and engaging in transactions with related parties (either domestic or cross-border) that exceed the 1,000 (one thousand) base salaries threshold from the corresponding year (approximately USD 745,000 for FY2019). The resolution became effective on 1 July 2019.
