On 26 October 2017, Costa Rica’s tax administration released a draft version of a resolution that would require multinational enterprises (MNEs) to file a country-by-country (CbC) report. According to draft resolution, all Costa Rican tax resident entities that are part of a Multinational Enterprise (MNE) Group with consolidated group revenue of €750 million and above (or its equivalent in local currency) will need to comply with the CbCR requirements for the reporting fiscal (tax) year. The CbC report will be submitted as an XML file, to an email address to be enabled by the tax administration, at least one month before the CbC report filing deadline.
The CbC report must be submitted by the last business day of the 12 month after fiscal year end. The taxpayer must notify the identity of the reporting entity. This notification must be submitted no later than the last day of the reporting fiscal period of the multinational group, using an official letter, which will be sent electronically and signed by the legal representative addressed to the tax director-general.
Failure to supply the information corresponding to the country-by-country report will be sanctioned in accordance with Article 83 of the Tax Standards and Procedures Code.
