Costa Rica Transfer Pricing Documentation Requirements
Costa Rica requires a Master File and Local File from every taxpayer engaged in related-party transactions, regardless of the amount and even where the dealings are purely domestic. Documentation is produced within ten days of a request, and the penalty is geared to a percentage of turnover.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Every taxpayer with related-party transactions (no threshold; domestic dealings included) | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 10 days. | ES | Yes (2% of prior-year turnover; 3 to 100 base salaries) |
Local File Required | Same scope as the Master File | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 10 days. | ES | Yes (2% of gross income; 3 to 100 base salaries) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Costa Rica deadline
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Scope of the documentation obligation
The regulation sets no threshold and does not require that the transactions be cross-border. Every taxpayer that engages in related-party transactions, regardless of the amount or whether the dealings are purely domestic, must prepare a Master File, and every taxpayer with intercompany transactions must prepare a Local File for production where the tax administration requires it. Documentation is produced within ten days of a request. A transfer pricing information return applies to defined taxpayers, including large taxpayers and free-trade-zone entities, although the tax authority has suspended the term for its submission until further notice.
Distinctive features of the Costa Rican regime
Two features distinguish the Costa Rican regime. The first is the breadth of scope: the obligation reaches purely domestic related-party transactions of any size, not just cross-border dealings, so the population caught is unusually wide. The second is the turnover-geared penalty, computed as 2 percent of the company’s turnover or gross income, subject to a floor of three base salaries and a cap of 100 base salaries, which for 2024 placed the range between roughly USD 2,700 and USD 90,000. The information return obligation exists in the rules but its filing term is currently suspended, so the live obligation is the documentation itself.
Benchmarking and comparables
There are no benchmarking requirements specifically directing local or regional comparables, and given the limited local financial information, international comparables are accepted. Multi-year testing of the comparables is used, in practice over three years. A fresh benchmarking search each year is preferred over a financial update of a prior study, and the report must be prepared annually, with the tax authority expecting the most recent comparable information. The standard limitation period is four years, extended to ten years for unregistered taxpayers, fraudulent returns, and failures to file.
Frequently asked questions
Does the Costa Rican requirement apply to domestic-only transactions?
Yes. The obligation reaches every taxpayer with related-party transactions regardless of the amount, and even where the dealings are purely domestic, not only cross-border transactions.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.