On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file.
The new resolution repeal the resolution DGT-R-16-2017 which was issued on 21 April 2017. Under the new resolution, all taxpayers who conduct transactions with related parties must keep the documentation confirming the similarity of their intragroup transactions with that of an independent party and the documentation that enables them to know and understand the operation and structure of the business group. Taxpayers must be prepared documentation based on BEPS action 13 recommended by OECD.
The Master file must cover the information including corporate structure; group administrative structure; documents showing the chain of suppliers of goods and services; list of the main markets; group intangibles; intragroup services; financing; description of the restructuring carried out during the last five years; total number of employees for each country; statement of consolidated income for the most recent period. The Local file is to include the administrative structure of the local entity, an organizational chart of the local entity, indicate to which persons the local manager’s report and indicate the countries where the persons to whom they are reported are located.
