Costa Rica: Final guidance on obligation of certain taxpayers to submit annual transfer pricing information return

The General Directorate of Taxation issued general resolution MH-DGT-RES-0026-2025 (“Resolution regarding the Submission of the Informative Transfer Pricing Return” effective August 4, 2025) providing final guidance regarding the obligation of certain taxpayers to submit an annual transfer pricing information return. 

• Obligation to submit an annual transfer pricing informative return for taxpayers who:
  • Are classified as large national taxpayers
  • Are beneficiaries of the free tax zone regime
• Carry out transactions with related parties that, separately or jointly, equal or exceed one thousand base salaries (approximately CRC 462,200,000 or US$920,000)
• The information return must be submitted within six months following the end of the taxpayer’s authorized fiscal period, starting with the 2025 fiscal year and onwards. The return for the 2024 fiscal year period must be submitted no later than November 30, 2025.
• The form must be submitted through the Integrated Tax Management System (TRIBU-CR). In the event of late submission or omission of information, the penalties set forth in Articles 83 and 150 of the Tax Code and Article 268 bis of the Tax Procedure Regulation will apply.
• The return templates and their instructions are included in Annexes 1 and 2 of the resolution. The Tax Administration may modify and publish them on its website with at least one month’s notice.

Read a July 2025 report (Spanish and English) prepared by the KPMG member firm in Costa Rica