Costa Rica’s Ministry of Finance, through the General Directorate of Taxation, has issued Resolution MH-DGT-RES-000-2025, which establishes new requirements for the annual transfer pricing disclosure for taxpayers engaged in transactions with related parties.
This measure is part of the broader Digital Treasury for the Bicentennial modernization project, funded by the World Bank, aimed at strengthening tax oversight and facilitating voluntary taxpayer compliance.
Key aspects of the resolution
- Who is required to file: The following corporate income taxpayers are required to submit the transfer pricing disclosure:
Those who engage in domestic or cross-border transactions with related parties and are classified as large taxpayers or operate under a free trade zone regime.
Those whose transactions with related parties, either individually or combined, exceed 1,000 base salaries in the corresponding fiscal year. As of now, one base salary equals ₡462,200 (approx. US $930).
- Filing deadline: The declaration must be submitted within three months following the close of the authorized fiscal period.
- TRIBU-CR platform: Submissions must be made exclusively through the TRIBU-CR system, which centralizes all tax procedures in a single electronic platform. Submissions through other channels will be considered invalid.
- Official form: The official declaration form and its instructions are included in the annexes to the resolution and will be available on the TRIBU-CR virtual office. The Tax Administration may update the format without issuing a new resolution, as long as changes are published on the institution’s website.
Penalties and responsibilities
Failure to file the declaration within the specified deadline, unless due to system failure, will result in administrative liability, and the taxpayer may be subject to administrative penalty procedures. Non-compliance will be penalized in accordance with Articles 83 and 150 of the Tax Code.
