Costa Rica: Transfer pricing return, procedures | KPMG | BE
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Costa Rica: Transfer pricing return, procedures are finalized

Costa Rica: Transfer pricing return, procedures

A resolution (Resolución No. DGT-R-44-2016) has been published in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return in Costa Rica.


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Taxpayers qualifying as “large taxpayers” or as “national large companies” or operating under a free trade zone regime and having intercompany transactions will be required to file a transfer pricing return. The transfer pricing return:

  • Will be filed electronically on a website platform as provided by the tax authority (Dirección General de Tributación)
  • Will consist of six sections for which taxpayers will provide information about each intercompany transaction as well as the details of the transfer pricing methods and results for each type of method selected
  • Will correspond to information contained in the taxpayer’s transfer pricing study that is prepared on an annual basis

Filing deadline

The transfer pricing return is to be filed on the last business day of June in the year following the tax year. The first transfer pricing return (for 2015) and the transfer pricing return for 2016 will both be due on the last business day of June 2017—in other words, the returns for 2015 and 2016 will be due at the same time.


Read a September 2016 report [PDF 82 KB] (Spanish and English) prepared by the KPMG member firm in Costa Rica

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