Tax Flash


Resolution DGT-R-001-2018 that deals with the presentation of the Country by Country Report in Costa Rica

February 9, 2018

Tax Flash

On February 2, the Costa Rica’s Tax Administration issued the Resolution DGT-R-001-2018 that deals with the presentation of the Country by Country Report in Costa Rica, which is part of the Transfer Pricing framework that has been implemented in Costa Rica which looks forward to aligning the country's tax legislation with the Transfer Pricing Guidelines established by the Organization for Economic Cooperation and Development.

In addition to this new obligation, taxpayers are required to prepare the Transfer Pricing Study and the Master File report on an annual basis, in case they are requested by the Tax Administration.

The most important aspects of this resolution are highlighted below:

Taxpayers obliged to present the Country-by-Country report:

  • Companies denominated "Higher Level Dominant Entity" or "Substitute Dominant Entity" that are a tax resident in the country and whose aggregate and accumulated income is equal to, or greater than 750 million euros or its equivalent in national currency.
  • There is no obligation to provide this information with respect to a specific tax period, if the Multinational Group has an obligation to provide the information for the same period through a Substitute Dominant Entity, resident abroad, to the foreign tax jurisdiction.


  • Any Entity that is a member of a Multinational Group that is a tax resident in Costa Rica, must notify the Costa Rican Tax Administration of its status as Reporting Entity, as a Higher Level Dominant Entity or Substitute Dominant Entity, of a certain Group or Multinational Group.
  • Said notification must be made no later than the last working day of the month of March of each year, beginning in the month of March 2018.

Form and deadline for submission:

  • The presentation of the Country-by-Country report must be done under the standard structure established by the OECD.
  • The electronic portal to submit such report will be announced one month in advance of the filing date.
  • The report corresponding to fiscal period 2017 must be submitted no later than December 31, 2018, regardless of its fiscal closing date.
  • For the following periods, the Group or Multinational Group must present the Country-by Country report on December 31 of the year following the end of the corresponding fiscal period.


  • Failure to supply the information required in this resolution will be sanctioned in accordance with article 83 of the Tax Rules and Procedures Code.


Alan Saborío
Country Managing Partner
Tax & Legal Leader

Carla Coghi
Tax and Legal Partner

Francisco Villalobos
Tax and Legal Partner

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