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Costa Rica: Considerations for preliminary transfer pricing reviews

Costa Rica transfer pricing reviews

Taxpayers with related-party or intercompany transactions need to consider the timely preparation of transfer pricing documentation in order to be able to respond satisfactorily to requests made by the tax authorities of Costa Rica.


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Typically, transfer pricing documentation is done at the end of the fiscal period. If irregularities are detected, tax adjustments may be warranted. In turn, this could affect the income tax declaration and result in inquiries from the tax authorities. A preliminary review of the transfer pricing situation could help address such possible contingencies and allow the taxpayer to promptly comply with requests from the Costa Rican tax authorities.

Taxpayers that currently do not have a transfer pricing policy, therefore, may want to consider conducting studies of their intercompany transactions based on the first three quarters of the available financial information. This exercise, if conducted before the end of the accounting period, may facilitate analysis of the intercompany transactions and may present an effective way to satisfy the transfer pricing requirements.


Read a November 2018 report (Spanish and English) [PDF 159 KB] prepared by the KPMG member firm in Costa Rica

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