Transfer Pricing Report - Costa Rica
Take Control of Transfer Pricing Costa Rica for Tax Clarity & Total Tax Compliance.
Costa Rica’s Transfer Pricing framework, established under Article 81 bis of the Income Tax Law (Law No. 7092) and Executive Decree No. 37898-H, requires all related-party transactions—domestic and cross-border—to comply with the arm’s-length principle.
Taxpayers must prepare Transfer Pricing documentation consistent with the OECD Transfer Pricing Guidelines and BEPS Action 13, supporting the commercial and financial terms of intercompany transactions.
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At Transfer Pricing Report, we deliver data-backed, defensible Transfer Pricing documentation that ensures alignment with DGT’s guidelines and OECD best practices.
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Answers to Your Transfer Pricing Concerns Costa Rica
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Still Have Questions?
Is Transfer Pricing documentation mandatory in Costa Rica?
Yes, Costa Rica requires Transfer Pricing documentation under Resolution DGT-R-49-2019.
A complete Transfer Pricing Study ensures compliance with Costa Rica’s arm’s length framework.
Does Costa Rica follow OECD Transfer Pricing Guidelines?
Yes, Costa Rica aligns its TP regulations with OECD principles for methods and comparability.
This ensures Transfer Pricing in Costa Rica meets international standards.
Which transactions require a Transfer Pricing Study in Costa Rica?
Transactions involving goods, services, financing, royalties, and IP with related parties must be documented.
A Transfer Pricing Study supports defensible pricing for entities in Costa Rica.
What documentation obligations apply in Costa Rica?
Costa Rica requires an Informative Return (D-162) and full TP documentation for qualifying taxpayers.
Accurate Transfer Pricing documentation ensures regulatory compliance in Costa Rica.
How does benchmarking work under Costa Rica’s TP rules?
Benchmarking compares related-party transactions with independent regional and global comparables.
This ensures Transfer Pricing outcomes in Costa Rica reflect arm’s length pricing.
What penalties apply for TP non-compliance in Costa Rica?
Costa Rica may impose penalties, adjustments, and interest for incomplete documentation.
Strong Transfer Pricing documentation reduces audit exposure in Costa Rica.
How often should Transfer Pricing documentation be updated in Costa Rica?
Annual updates are advised to reflect financial and operational changes.
Regular updates help maintain accurate Transfer Pricing compliance in Costa Rica.
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