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Costa Rica: Transfer pricing documentation guidelines (Master and Local files)

Costa Rica: Transfer pricing documentation guidelines

The Costa Rica tax authority (Dirección General de Tributación) on 13 November 2019, issued a resolution—DGT-R-49-2019—providing new guidelines with respect to transfer pricing documentation and concerning the rules for Master file and Local file documentation.


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With the new guidance, a resolution from 2017 (DGT-R-16-2017) has been repealed.

The new guidelines provide that all taxpayers conducting transactions with related companies must retain documentation that supports their position that their intercompany transactions are similar to those with an independent party, as well as documentation that allows the tax authority to understand the operation and structure of the business group. The documentation that must be prepared by taxpayers in Costa Rica is based on the OECD’s base erosion and profit shifting (BEPS) Action 13.

The Master file must cover the following points:

  • 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
  • A chart showing the total number of employees for each country
  • A copy of the statement of consolidated income for the most recent period

The Local file is to include a description of the administrative structure of the local entity, and when the intercompany transactions of the taxpayer are requested, information about:

  • Identification and documentation of other controlled transactions that may directly or indirectly affect the price of those transactions
  • Specific reasons why a multi-year analysis is applied
  • Audited financial statements of the previous three years

Read a November 2019 report (Spanish and English) [PDF 35 KB] prepared by the KPMG member firm in Costa Rica

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