Costa Rica: APA guidelines

Costa Rica: APA guidelines

The tax authority published guidelines for processing and implementing advance pricing agreements (APAs).


The guidelines—resolution DGT-R-14-2021—establish the APA process for taxpayers that regularly conduct the same or similar transactions with related parties.

The APA, an agreement between taxpayers and the tax authority, establishes an appropriate set of criteria, procedures, and assumptions in advance of the transaction to determine the transfer prices of selected transactions for a specified period of time. With the APA, the tax authority confirms that it agrees to the transfer pricing analysis in advance of the transaction.

Read a March 2021 report (Spanish and English) [PDF 147 KB] prepared by the KPMG member firm in Costa Rica

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