Meet your tax obligations in related-party transactions with technical documentation, defensible analysis, and specialized support.
What Your Company Needs to Keep in Mind in Costa Rica
Tax Authority
Compliance with transfer pricing regulations is reviewed by the General Tax Directorate (DGT).
Companies with transactions between related parties may be subject to the Transfer Pricing Information Return and must have supporting documentation to demonstrate that their transactions comply with the arm’s-length principle.
Key Obligations
A lack of supporting documentation may result in financial penalties, tax adjustments, interest, surcharges, or increased exposure to audits by the tax authority.
Risks of Noncompliance
Compliance deadlines in Costa Rica depend on the applicable tax period: March 31, 2026: Transfer Pricing Information Return for the 2024 tax period.
June 30, 2026: Transfer Pricing Information Return for the 2025 tax year.
For subsequent periods, the general deadline will be six months following the authorized fiscal year-end, as applicable.
Functional analysis of functions, assets, and risks.
Benchmarking or comparability analysis, where applicable.
Identification of the related parties involved.
Financial information on the taxpayer and the transactions analyzed.
Elements that typically form part of the analysis
In Costa Rica, taxpayers who engage in transactions with related parties must demonstrate that their revenues, costs, and deductions were determined in accordance with the arm’s-length principle; that is, under conditions comparable to those that independent parties would have agreed upon in similar transactions.
Transfer pricing documentation helps substantiate the reasonableness of intercompany transactions, support the Informative Return when applicable, and provide technical evidence in the event of potential requests from the General Tax Administration.
Compliance in Costa Rica requires demonstrating that related-party transactions are conducted under market conditions
Selection of the applicable transfer pricing method.
Description of the intercompany transactions carried out.
Review of contracts, invoices, and supporting documentation.
Conclusion regarding compliance with the arm’s-length principle.
Download the Transfer Pricing Compliance Roadmap for Costa Rica
Review in a single document the key steps, dates, and obligations your company must address to properly comply with Costa Rican regulations.
Before ensuring compliance in Costa Rica, check to see if you have:
Clear identification of transactions with related parties.
A review of applicable obligations based on taxpayer profile, Free Trade Zone status, or transaction volume.
Contracts, invoices, and supporting documentation.
A functional analysis of the entities involved.
Up-to-date and segmented financial information.
Benchmarking or comparability analysis, when applicable.
Consistency between intercompany policy and the group’s actual operations.
Documentation prepared in case it is requested by the DGT.
Leaders in Transfer Pricing Advisory Services in Latin America
Our team can assist you in reviewing, preparing, or strengthening your transfer pricing documentation in Costa Rica, taking into account local regulations and your business group’s actual operations.
Local Documentation
Benchmarking
Review of Intercompany Policies
Support during audits or in response to regulatory requests
We assist business groups with operations in various countries across the region, combining local compliance, a regional perspective, and specialized technical support.
+1,200
Annual Studies
Why Choose Grupo Consultor EFE® for Your Transfer Pricing Compliance
Experience in documenting and analyzing intercompany transactions.
+600
clients
Support for local businesses, business groups, and companies with international operations.
Support in Costa Rica and other Latin American countries for companies with multinational structures.
Integrated Vision
Local + Regional
Technical + Strategic
Differentiated
Documentation prepared to comply with, support, and defend the transaction during audits.
At Grupo Consultor EFE®, we understand that transfer pricing compliance is not merely a tax obligation. It can also serve as a tool to strengthen decision-making, assess the efficiency of intercompany transactions, and anticipate risks in an increasingly regulated environment.
The support they provide throughout the entire process is consistent and highly responsive. Their commitment to completing each stage is evident, as is the high level of professionalism with which they approach every project. Their approach builds trust from the start, and the results clearly reflect their serious and responsible approach. The way they engage and deliver on their promises is truly exemplary.
Companies That Have Placed Their Trust in Us
Real results from business groups that demonstrate their compliance with our technical support.
Rosa Delia Silva Pineda
Flextronics
"
Working with your team has been a positive experience from start to finish. From our very first contact, they demonstrated a high level of professionalism, attention to detail, and clarity in communication. The results we achieved were fully in line with our expectations, which confirms the quality and effectiveness of your services.
Argentina Hidalgo
EMASAL Group
"
It was my first time working on transfer pricing; the support and follow-up were excellent and appropriate. At our corporate office in San Diego, we were asked to conduct a transfer pricing study; previously, our company’s accounting functions were handled by an external firm, and they were the ones who recommended Grupo Consultor EFE® to us.
Pablo Rafael Xep
CPS
"
Transfer pricing regulations in Costa Rica are primarily set forth in the Income Tax Law, the Regulations of the Income Tax Law, Decree 37898-H, and resolutions issued by the General Directorate of Taxation.
These provisions establish that transactions between related parties must be valued in accordance with the arm’s-length principle, supporting documentation must be retained, and an Informative Return must be filed when the taxpayer falls under the applicable circumstances.
Regulatory Laws Governing Transfer Pricing in Costa Rica
Decree 37898-H established the general guidelines for the application of transfer pricing in Costa Rica, including the arm’s length principle, the definition of related parties, accepted methods, and documentation requirements.
Subsequently, the General Taxation Directorate issued resolutions related to the Transfer Pricing Informative Return and to documentation aligned with international standards. Resolution MH-DGT-RES-0026-2025 reinstated the requirement for certain taxpayers to file the annual Informative Return and established specific filing rules.
Applicable Legislation
in Costa Rica
Definition of a Related Party in Costa Rica
In Costa Rica, related parties are considered to be individuals, legal entities, or organizations resident in the country or abroad when one participates directly or indirectly in the management, control, or capital of the other, or when the same persons participate directly or indirectly in the management, control, or capital of both.
Related party relationships may also exist when one entity exercises systematic influence over another’s pricing decisions, when there is a significant stake in capital or voting rights, when multiple entities form part of the same decision-making unit, or in the case of permanent establishments, parent companies, distributors, or exclusive agents.
The correct identification of related parties is essential for determining whether there is an obligation to analyze, document, and file the Informative Return.
Transfer Pricing Information Return
The Transfer Pricing Information Return applies to taxpayers who engage in transactions with related parties and who fall under the circumstances established by Costa Rican regulations.
Those subject to this requirement may include large domestic taxpayers, companies operating under the Free Trade Zone regime, and taxpayers with related-party transactions that exceed the threshold established in base salaries.
Key Dates:
March 31, 2026: Transfer Pricing Information Return for the 2024 tax year.
June 30, 2026: Transfer Pricing Information Return for the 2025 tax year.
For subsequent periods, the general deadline will be six months following the authorized fiscal year-end, as applicable.
Supporting Documentation
Taxpayers engaged in transactions with related parties must maintain sufficient documentation to demonstrate that their transactions comply with the arm’s-length principle.
This documentation may include activities and functions performed, assets used, risks assumed, general information about the business group, financial statements, transfer pricing methods used, identification of intercompany transactions, and relevant documentation supporting the transactions.
Retention and Submission of Documentation
Supporting documentation must be retained for the period specified by the Code of Tax Rules and Procedures. In Costa Rica, the general retention period is four years.
The Transfer Pricing Study must be prepared and available for submission to the General Directorate of Taxation upon formal request.
Language of the Documentation
Documentation submitted to the tax authority must be prepared in Spanish.
Costa Rican law does not provide for special treatment for small and medium-sized enterprises with regard to transfer pricing. Therefore, obligations must be reviewed based on the type of taxpayer, applicable tax regime, volume of transactions, and the provisions set forth in current regulations.
Transfer pricing documentation must be prepared prior to the filing of the Informative Return, as it serves as supporting evidence for the reported information and to address any potential requests from the tax authority.
In practice, the study must be available before the filing deadline for the Informative Return or before any formal request from the DGT.
In accordance with the Code of Tax Rules and Procedures, taxpayers must retain the books, files, records, and supporting documents necessary for tax audits and the determination of tax obligations for the period specified by applicable regulations.
Generally speaking, the retention period in Costa Rica is four years.
Costa Rican regulations provide for various methods to assess whether transactions between related parties are conducted in accordance with the arm’s-length principle.
Accepted Methods:
The selection of the method must take into account the nature of the transaction, the availability of comparable information, the functions performed, the assets used, and the risks assumed by the parties involved.
Costa Rican law permits the use of both internal and external comparables to determine whether transactions between related parties comply with the arm’s-length principle.
The analysis must consider the characteristics of the transaction, the functions performed, the assets used, the risks assumed, the contractual terms, economic circumstances, and business strategies.
Costa Rica is a member of the Inclusive Framework on BEPS and has adopted commitments related to the project’s minimum standards, including harmful tax practices, prevention of treaty abuse, country-by-country reporting, and dispute resolution mechanisms.
With regard to transfer pricing, the regulations and resolutions issued by the General Directorate of Taxation have sought to strengthen the documentation, transparency, and traceability of transactions between related parties.
Failure to comply with transfer pricing reporting and documentation obligations may result in financial penalties, tax adjustments, interest, surcharges, and increased exposure to audits by the tax authorities.
Failure to provide information may result in a penalty equivalent to 2% of the violator’s gross revenue for the previous tax period, with minimum and maximum amounts set in terms of base salaries. In the event of errors in the information provided, additional penalties may be imposed for incorrect records, in accordance with the Code of Tax Rules and Procedures.
Check your company’s compliance in Costa Rica
Schedule a conversation with our team to find out if your related-party transactions have the necessary technical support to ensure proper compliance in Costa Rica.
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