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Costa Rica: Transfer pricing guidance

Costa Rica: Transfer pricing guidance

The tax authority in Costa Rica issued guidance concerning transfer pricing rules and specifically defining related parties and setting forth rules for residents of low-tax jurisdictions as well as transfer pricing return requirements for certain entities.


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Resolution N° 41818-H (Spanish), as published on the official gazette in late June 2019, is effective 1 July 2019 and addresses:

  • Related parties and residents in jurisdictions with income tax rates of 18% or lower or that do not have a tax information exchange agreement with Costa Rica
  • Transfer pricing return requirements for entities operating under a free trade zone system or that are identified as “large taxpayers” under the GETES (large territorial company) program and that engage in transactions (either domestic or cross-border) with related parties and that exceed certain threshold amounts

The regulation does not establish a deadline regarding the filing of the transfer pricing return.

Read a July 2019 report (Spanish and English) [PDF 123 KB] prepared by the KPMG member firm in Costa Rica

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