Costa Rica: Advance pricing agreements, implementing guidance

Costa Rica: Advance pricing agreements, guidance

The tax administration issued a resolution (DGT-R-14-2021) providing guidance regarding the procedures for implementing advance price agreements (APA).


The APA process allows taxpayers that regularly conduct transactions with related parties to manage their transfer pricing obligations, in that the tax authority effectively agrees to the taxpayer’s transfer pricing analysis in advance of the transactions. The APA is voluntarily concluded by the taxpayers and the tax administration, with both parties agreeing in advance to the criteria, procedures and assumptions with regard to the transfer prices in identified transactions to be conducted during a specified period.

Read an April 2021 report (Spanish and English) [PDF 178 KB] prepared by the KPMG member firm in Costa Rica

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