Executive summary

On 25 July 2025, the Costa Rican Tax Administration published in the Official Gazette Resolution No. MH-DGT-RES-0026–2025 (the Resolution), related to the filing of the Transfer Pricing Informative Return (Declaración Informativa en Materia de Precios de Transferencia). This Resolution establishes the obligations and formalities for taxpayers required to file this informative return. The Resolution will enter into force on 4 August 2025.

Obligated taxpayers

According to the Resolution, the following Corporate Income Taxpayers are required to file the Transfer Pricing Informative Return annually:

1. Large National Taxpayers conducting domestic or cross-border transactions with related parties
2. Free Trade Zone Regime taxpayers conducting domestic or cross-border transactions with related parties
3. Taxpayers conducting domestic or cross-border related-party transactions, where the aggregate amount of the transactions during the fiscal year exceeds 1,000 base salaries, either individually or jointly

Filing deadline

The Transfer Pricing Informative Return must be submitted within six months following the end of the authorized fiscal year of the taxpayer and should include all related-party transactions conducted during the corresponding Corporate Income Tax fiscal year.

Transitional provision

For fiscal year 2024, the Transfer Pricing Informative Return must be submitted by 30 November 2025, as established in the transitional provision of the Resolution.

Implications

Multinational and local entities should review their related-party transactions and report timelines to help ensure compliance with the new filing requirements.