Since the adoption of the transfer pricing regulations in 2013, Costa Rica has made progress in implementing measures to strengthen tax transparency. One such measure is the transfer pricing informative return. However, despite an earlier attempt to introduce a filing requirement in 2017, it was not until July 24, 2025, that the General Directorate of Taxation formally published Resolution MH-DGT-RES-0026-2025 to officially establish the transfer pricing informative return reporting obligation.
The annual transfer pricing informative return must be filed by:
The return must be submitted through the virtual platform of the TRIBU-CR system, ensuring a secure and digitalised process for taxpayers.
Failure to submit the informative return by the established deadline may result in penalties. The applicable fine is 2% of the gross income declared by the taxpayer in the previous fiscal period, with a minimum of three base salaries (CRC 1,386,000 or approximately USD 2,772) and a maximum of 100 base salaries (CRC 46,200,000 or approximately USD 91,485).
To comply with the filing obligation, the informative return must include:
The implementation of the transfer pricing informative return requirement in Costa Rica marks a milestone in the development of the country's transfer pricing regime. It ensures greater transparency in related-party transactions and strengthens tax compliance. Taxpayers must adequately prepare to meet this new requirement, avoid penalties, and ensure the proper submission of the required information. In this context, the timely preparation of a transfer pricing study is key to a successful and smooth filing process.
It is important to emphasise that this informative return is mandatory for large taxpayers, Free Trade Zone Regime beneficiaries, and those whose related-party transactions — whether individually or jointly — exceed 1,000 base salaries. However, other taxpayers engaging in related-party transactions that do not meet these criteria must still prepare a transfer pricing study. Although they are not required to file the informative return, they must have the study available to demonstrate to the tax authorities that their related-party transactions are conducted at arm’s length.
Lorna Medina Calvo
BDO in Costa Rica
Taxpayers Required to File Informative Return
The annual transfer pricing informative return must be filed by:
- Taxpayers that engage in domestic or cross-border transactions with related parties and are classified as “large national taxpayers” or that are beneficiaries of the Free Trade Zone regime; and
- Taxpayers whose related-party transactions, whether individually or collectively, exceed 1,000 base salaries (CRC 462,000,000 or approximately USD 914,852).
Deadlines for Filing Informative Return
According to the resolution, starting with the 2025 tax year, the return must be submitted within six months after the end of the taxpayer’s authorised fiscal period. For the 2024 tax year, the return must be submitted no later than November 30, 2025.
Filing Procedure
The return must be submitted through the virtual platform of the TRIBU-CR system, ensuring a secure and digitalised process for taxpayers.
Consequences of Noncompliance
Failure to submit the informative return by the established deadline may result in penalties. The applicable fine is 2% of the gross income declared by the taxpayer in the previous fiscal period, with a minimum of three base salaries (CRC 1,386,000 or approximately USD 2,772) and a maximum of 100 base salaries (CRC 46,200,000 or approximately USD 91,485).
Contents of Informative Return
To comply with the filing obligation, the informative return must include:
- General information about the taxpayer and related parties
- Details of transactions with related parties, including:
- Amount of the transactions
- Transfer pricing method used
- Adjustment according to the arm’s length principle
- Other relevant information as specified in the resolution
Conclusion
The implementation of the transfer pricing informative return requirement in Costa Rica marks a milestone in the development of the country's transfer pricing regime. It ensures greater transparency in related-party transactions and strengthens tax compliance. Taxpayers must adequately prepare to meet this new requirement, avoid penalties, and ensure the proper submission of the required information. In this context, the timely preparation of a transfer pricing study is key to a successful and smooth filing process.It is important to emphasise that this informative return is mandatory for large taxpayers, Free Trade Zone Regime beneficiaries, and those whose related-party transactions — whether individually or jointly — exceed 1,000 base salaries. However, other taxpayers engaging in related-party transactions that do not meet these criteria must still prepare a transfer pricing study. Although they are not required to file the informative return, they must have the study available to demonstrate to the tax authorities that their related-party transactions are conducted at arm’s length.
Lorna Medina Calvo
BDO in Costa Rica