Costa Rica: Master file, Local file requirements | KPMG | GLOBAL
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Costa Rica: Master file, Local file and other recordkeeping requirements

Costa Rica: Master file, Local file requirements

Costa Rica’s tax authority (Dirección General de Tributación—DGT) issued guidance on 21 April 2017 requiring taxpayers having transactions with related parties to retain supporting documentation of certain corporate information and company local information.


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The corporate information required by the DGT is the equivalent to the “Master file” that summarizes qualitative and quantitative data from the group at the international level, as propose by the OECD in the base erosion and profit shifting (BEPS) project. Also, taxpayers in Costa Rica need to preserve local taxpayer company data, such as the organization structure, chain value, financial information, transfer pricing politics, and other more. This documentation requirement is the equivalent to the “Local file” rules under BEPS Action 13.

The DGT resolution establishes a requirement for additional information—in addition to the transfer pricing study. This documentation has no specific date of presentation, but must be provided by the taxpayer only on request of the DGT, and must be provided in the Spanish language. Failure to comply with this provision could lead to a penalty of an amount up to approximately U.S. $90,000.


Read an April 2017 report (Spanish and English) [PDF 112 KB] prepared by the KPMG member firm in Costa Rica


For more information, contact a tax professional with KPMG in Costa Rica:

Sergio García | +506 2201-4292 |

Álvaro Castro | +506 2201-4189 |

José Rodríguez| +506 2201-4123 |

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