Costa Rica has taken a significant step toward strengthening its Transfer Pricing regime by issuing Resolution MH-DGT-RES-0026-2025, which establishes the obligation to file an Annual Informative Affidavit on transactions with related parties.
The Role of Transfer Pricing in Modern Tax Auditing
Transfer pricing is one of the main mechanisms used by tax authorities to verify that transactions between related companies are conducted under arm’s length conditions. In an increasingly globalized economic environment, where multinational groups operate across multiple jurisdictions, tax authorities have stepped up their efforts to ensure that profits are taxed where they are actually generated.
Consequently, the collection of information on intra-group transactions has become a fundamental tool for tax risk management and the protection of tax bases.
Who is required to file?
The resolution establishes that the following must file the return:
- Large National Taxpayers.
- Companies operating under the Free Trade Zone Regime.
- Taxpayers conducting transactions with related parties for amounts equal to or exceeding 1,000 base salaries.
The obligation applies to both domestic and international transactions, significantly expanding the scope of tax oversight.
A trend aligned with the region
The implementation of transfer pricing information returns is a trend that has taken hold in Latin America over the past decade. Countries such as Peru, Colombia, Mexico, and Chile have strengthened their reporting mechanisms with the aim of improving tax risk management and combating tax base erosion.
Costa Rica’s decision reflects the growing importance of tax transparency and the need for structured information to evaluate intra-group transactions.
Implications for companies
Organizations subject to this requirement must review their Transfer Pricing policies, validate the consistency of their supporting documentation, and ensure that the reported information matches their tax returns and financial statements.
Failure to comply or the incorrect submission of information may result in administrative penalties and an increased risk of an audit.
In a context of increasing tax scrutiny, it is essential that companies adopt a preventive strategy that allows them to demonstrate that their transactions with related parties are aligned with the arm’s length principle.
At TPC Group, we have a team specialized in Transfer Pricing that assists companies in complying with their tax obligations, preparing technical documentation, and managing tax risks in Costa Rica and throughout Latin America.
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