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.
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 | email@example.com
Álvaro Castro | +506 2201-4189 | firstname.lastname@example.org
José Rodríguez| +506 2201-4123 | email@example.com
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.