On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions and competent authority for APAs; documentation requirements for related-party transactions; a processing time of six months, with a potential six-month extension; an APA validity period of five fiscal years; the procedure for new applications, renewals, and modifications of existing APAs; a requirement to submit annual reports by the last business day of the third month after the end of the relevant fiscal period; confidentiality provisions; and grounds for the cancellation of APAs.
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