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Valuation of Intragroup Financial Transactions in Costa Rica according to OECD guidelines
By Gabriela Páez In recent years, intragroup financial transactions have become a major focus of attention in transfer pricing. Operations such as related-party loans, financial guarantees, and cash-pooling arrangements, which were traditionally documented using general criteria, are now subject to more technical analysis by tax authorities. This change reflects the evolution of the OECD Transfer Pricing Guidelines, which incorporated specific criteria for these types of tr
EAS LATAM
Dec 19, 20254 min read


Long-term leases: the silent impact that changed EBITDA, debt, and management reporting. IFRS 16.
By Rebeca Sequeira Since its implementation, IFRS 16 Leases has changed how companies present their financial statements. In Costa Rica and the rest of the region, this standard has required a review of management indicators, contracts, and projections, especially in sectors with a high volume of leases, such as hospitality, retail, transportation, and manufacturing. Today, several years after its adoption, it is a good time to review what has changed in financial analysis, h
EAS LATAM
Nov 17, 20254 min read


Intra-group services and the 5 % mark-up: simplification under OECD guidance.
By Gabriela Páez What is a Safe Harbor regime? A Safe Harbor, literally translated as "safe harbor", is a legal or administrative provision by which the Tax Administration accepts, in advance and without question, the prices or margins applied in certain transactions between related companies, whether they are companies of the same owner or controlled by the same group. Its purpose is to simplify tax compliance, reduce administrative costs, and provide certainty to companies
EAS LATAM
Oct 31, 20254 min read
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