In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs).
The draft guidelines state that APA applications would need to be addressed to the general tax office and submitted to the General Taxation Directorate office together with information required by resolution DGT-R-049-2019 in relation to Master file and Local file requirements.
The APA will be in force for five fiscal periods and could be granted in two ways- (i) The fiscal period in which the APA application is submitted and the following four fiscal periods. (ii) The five years beginning in the fiscal period after the date of submission of the APA application. The resolution will enter into force after it is finalized and published in the Official Gazette.
