New Obligations for Large Taxpayers and Free Trade Zone Companies
In order to reinforce tax control and ensure compliance with the Arm’s Length Principle, the General Directorate of Taxation of Costa Rica issued Resolution No. MH-DGT-RES-0026-2025, by which it establishes the obligation to file the Annual Information Transfer Pricing Statement through the Integrated Tax Management System TRIBU-CR.
This provision is part of implementing the technological tools promoted by the Digital Treasury for the Bicentennial project, with the support of the International Bank for Reconstruction and Development, aimed at modernizing tax management and facilitating voluntary compliance by taxpayers.
Entities Subject to Tax Return
According to Article 2 of the resolution, the following taxpayers must file this information statement:
- Large domestic taxpayers with related party transactions, whether domestic or cross-border.
- Companies in free trade zone regimes with domestic or cross-border related-party transactions.
- Taxpayers performing related party transactions that together or separately exceed 1,000 base salaries in the corresponding fiscal year
Deadlines and Filing Format
The information statement must be filed within six months following the fiscal period-end authorized by the taxpayer. For the 2024 fiscal period, the specific deadline is November 30, 2025.
The respective form will be available exclusively in the Virtual Office of the TRIBU-CR system, as indicated in General Resolution No. MH-DGT-RES-0017-2025. The Administration can update this form after publishing it for at least one month in advance without issuing a new resolution.
Non-compliance Penalties
Failure to file the statement within the designated timeframe is an administrative infraction under Article 83 of the Tax Code, with penalties outlined in Articles 150 of the Code and 268 bis of the Tax Procedure Regulations.
Modernization and Digital Tax Control
This resolution enables the Costa Rican Tax Administration to reaffirm its policy of digitalization and intelligent auditing, promoting transparency in related-party transactions and ensuring a correct determination of taxes on profits.
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 related party transactions in Costa Rica?
Check if you must file the Transfer Pricing information statement, and prepare in advance to comply with the TRIBU-CR system requirements.
Get Transfer Pricing advice and avoid penalties.
Source: Resolution No. MH-DGT-RES-0026-2025 - Ministry of Finance of Costa Rica. Published on July 10, 2025.