Costa Rica formalizes new Informative Affidavit on Transfer Pricing
New obligations for large taxpayers and companies in the Free Trade Zone
In order to strengthen tax control and ensure compliance with the principle of free competition, the Costa Rican Tax Authority issued Resolution No. MH-DGT-RES-0026-2025, which establishes the obligation to file an Annual Transfer Pricing Informative Affidavit through the TRIBU-CR Integrated Tax Management System.
This provision is part of the implementation of technological tools promoted by the Hacienda Digital para el Bicentenario (Digital Treasury for the Bicentennial) project, with support from the International Bank for Reconstruction and Development, whose objective is to modernize tax administration and facilitate voluntary compliance by taxpayers.
Who is required to file?
According to Article 2 of the resolution, the following taxpayers must file this informative affidavit:
- Large national taxpayers that carry out transactions with related parties, whether domestic or cross-border.
- Companies under the Free Trade Zone regime that carry out transactions with related parties, whether domestic or cross-border.
- Taxpayers who carry out transactions with related parties and who, jointly or separately, exceed 1,000 base salaries in the corresponding fiscal year.
Deadlines and filing format
The Informative Affidavit must be filed within six months after the end of the tax period authorized by the taxpayer. For the 2024 tax period, the specific deadline is November 30, 2025.
The respective form will be available exclusively at the Virtual Office of the TRIBU-CR system, as indicated in General Resolution No. MH-DGT-RES-0017-2025. This form may be updated by the Administration without the need to issue a new resolution, provided that it is published at least one month in advance.
Penalties for non-compliance
Failure to file the return within the established deadline will be considered an administrative offense under Article 83 of the Tax Code and will result in penalties under Articles 150 of the Code and 268 bis of the Tax Procedure Regulations.
Modernization and digital tax control
With this resolution, the Costa Rican Tax Administration reaffirms its policy of digitization and smart taxation, promoting transparency in transactions between related parties and ensuring the correct determination of income tax.
The use of the TRIBU-CR system not only strengthens tax control but also facilitates the process for taxpayers through a unified, modern, and accessible channel.
Call to Action:
Do you have transactions with related parties in Costa Rica?
Check if you are required to file the Informative Transfer Pricing Affidavit and prepare in advance to comply with the requirements of the TRIBU-CR system.
Get advice from experts in Transfer Pricing and avoid penalties.
Source:
Resolution No. MH-DGT-RES-0026-2025 – Costa Rican Ministry of Finance. Published on July 10, 2025.