Costa Rica’s Directorate-General of Taxation has published a notice in the Official Gazette announcing a public consultation on a draft resolution on 13 February 2025.
The resolution pertains to submitting the informative statement on transfer pricing by large taxpayers and beneficiaries operating in free trade zones.
This transfer pricing statement requirement was introduced in 2016 but was suspended a year later. The new draft resolution reinstates the requirement for large taxpayers and free zone operators to submit transfer pricing statements if their transactions with related companies exceed 1,000 base salaries annually.
The base salary for 2025 is set at CRC 462,200, establishing a submission threshold of CRC 462,200,000.
When applicable, the transfer pricing informative statement must be submitted electronically via the TRIBU-CR System.
The resolution contains the form for the informative statement, and detailed instructions have also been included. The form covers related companies, tangible and intangible assets and property transactions, financial operations, and other services.
The information return must be submitted within three months after the fiscal period ends through the TRIBU-CR system’s virtual office.
For the 2024 fiscal period, it must be submitted within six months of the resolution’s effective date.
When implemented, this resolution will supersede the previous resolutions issued in 2016 and 2017.
