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Costa Rica: Proposed changes to country-by-country reporting rules

Costa Rica: Proposed changes to CbC reporting rules

Costa Rica´s tax administration issued a draft amendment that would modify certain guidance relating to entities required to file a country-by-country (CbC) report.


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The draft amendment would modify Articles 2, 3, and 5 of Resolución N° DGT-R-001-2018 concerning CbC reporting. Specifically, entities required to file the CbC report would be the “ultimate parent entities” or the “surrogate parent entities” belonging to the same multinational enterprise (MNE) groups that are residents of Costa Rica. Thus, this change would exclude companies of “national groups.”  

The proposed modifications would not affect a current requirement that the tax administration must be notified when an entity is designated by the MNE group to serve as the ultimate parent entity or the surrogate parent entity and would not modify the form or terms for filing the CbC report.


Read an October 2018 report (Spanish and English) [PDF 173 KB] prepared by the KPMG member firm in Costa Rica

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