On 30 January 2020, the Costa Rican Official Gazette published a law introducing a three-month moratorium on the Registry of Transparency and Final Beneficiaries (RTBF) registration penalties for the 2019 tax year. The Registry was established as part of Law 9416, which requires taxpayers to submit an annual return with the Registry starting with tax year 2019 and thereafter. Taxpayers were required to start filing the annual return in September 2019. The due date for the return depended on the last digit of the entity’s taxpayer identification number. The last day for filing the annual return without penalties was 31 January 2020.

The law includes that no penalty will apply to declarations for the first two months; 50 % of the normal penalty amount applies for the third month; and regular sanctions for noncompliance resume at the end of the third month. The Law is effective and the moratorium begins as of the publication date.