Jun 29, 2026
By Gabriela Páez
In Costa Rica, the General Directorate of Taxation classifies taxpayers as Large National Taxpayers when, due to their level of operations, assets, assessed taxes, or business relationships, they have significant fiscal importance for the Tax Administration.
Resolution DGT-R-22-2021 establishes the criteria used for this classification. Some are numerical, such as the average amount of assessed taxes, declared gross income, and declared total assets. Others relate to the way the company is connected to an economic group, for example, whether it is part of a business group linked to a Large National Taxpayer or whether it assumes operations from a company that is already in that category.
This means that a company may fall within this classification not only because of its size, but also because of the way it is connected to other companies in the group. For this reason, corporate structure, ownership, management, control, and operational integration are matters that should be clearly identified.
One of the most important obligations for this group is to have financial statements audited by an independent Certified Public Accountant. Under Resolution MH-DGT-RES-0002-2024, these reports must be submitted when requested by the Tax Administration. In addition, if the company reports a tax liability equal to zero or a negative taxable base, it must submit them without waiting for a prior request.
This obligation must be fulfilled within three months after the close of the fiscal period corresponding to income tax. It is also possible to request an extension for an equal period, provided that the company can properly justify it.
The audited financial statements must be submitted in Spanish and in Costa Rican colones. They must also include the auditor’s report, the basic financial statements, explanatory notes, comparative information from the previous period, and the corresponding tax reconciliation.
In practice, this encourages companies classified as Large National Taxpayers to review their information in advance. It is not only about preparing financial statements at year-end, but also about maintaining a clear connection between accounting records, the income tax return, tax reconciliation, and supporting documentation for relevant transactions.
Another topic to keep in mind is transfer pricing compliance. Large National Taxpayers are among those required to have an annual study, which must be available if requested by the Tax Administration, together with the related financial information.
In this context, preparing in advance makes a significant difference. A company that keeps its records up to date, its accounting policies documented, its reconciliations reviewed, and its related-party transactions properly supported is in a better position to address reviews, controls, or audits.
Main taxpayer responsibilities
Responsibility | What does it involve? | Why is it important? |
Keep accounting and tax information up to date | Maintain clear records, reviewed reconciliations, and complete supporting documentation for relevant transactions. | Allows the company to respond with greater confidence to reviews, requests, or audit processes. |
Submit audited financial statements | Submit financial statements audited by an independent Certified Public Accountant when applicable. | Strengthens financial transparency and facilitates review of the company’s economic situation. |
Meet established deadlines | Submit documentation within three months after fiscal year-end, or request an extension when necessary and justifiable. | Helps avoid formal noncompliance, penalties, and unnecessary risks. |
Prepare the tax reconciliation | Properly connect the accounting information with the income tax return. | Helps explain differences between financial results and the declared taxable base. |
Support related-party transactions | Maintain adequate documentation, including the annual transfer pricing study when applicable. | Reduces risks in transactions with related companies and demonstrates that transactions are carried out under reasonable conditions. |
Adopt preventive tax management | Review policies, processes, and documentation before fiscal year-end, not only when a request is received. | Turns tax compliance into part of the company’s financial governance. |
Being a Large National Taxpayer means working under a higher compliance standard. For this reason, tax management should be seen as a natural part of the company’s financial governance, not as a task addressed only at fiscal year-end.
References
General Directorate of Taxation (Dirección General de Tributación). Resolution DGT-R-22-2021, "Criteria for the Classification of Large National Taxpayers."
General Directorate of Taxation (Dirección General de Tributación). Resolution MH-DGT-RES-0002-2024, "Amendments and Additions to Resolution DGT-R-46-2014, regarding the obligation of Large National Taxpayers to present audited financial statements prepared by a certified public accountant."
Ministry of Finance (Ministerio de Hacienda). Tax Management Directorate for Large National Taxpayers (Dirección Gestión Tributaria de Grandes Contribuyentes Nacionales). Institutional presentation on Large National Taxpayers, March 2026..