Mar 23, 2026
By MSC. Gabriela Páez. Tax Manager
To begin with, as simple as this: if the numbers do not “match” the activity of the business, the audit starts. This responds to the technological integration among TRIBU-CR, electronic invoicing, and the new monthly informative returns, which allows the Administration to analyze the financial behavior of each taxpayer in almost real time.
One of the most relevant changes was the replacement of the annual informative return D-151 with the monthly D-270 form, which requires reporting information on clients and suppliers on a monthly basis. This adjustment, widely discussed in the media, implies that the Administration no longer has to wait until the closing of the fiscal period to know the taxpayer’s commercial structure. They have the information in hand. What used to be analyzed once a year is now reviewed month by month.
In practice, this means that the Tax Authority can cross-check:
a) Issued and received electronic invoices
b) VAT returns
c) D-270 informative returns
d) Withholdings
e) The income tax return
If the sales invoiced electronically are not consistent with the declared profit, the system detects it immediately.
What Has Been Publicly Stated: Sale of Invoices and Platform Cross-Checks
Recently, in a television interview, former Minister of Finance and current elected congressman Nogui Acosta stated that the Tax Administration detected a company dedicated to issuing invoices for approximately CRC 50 billion to fraudulent taxpayers, further indicating that the Administration will pursue both the party issuing them and those who used them. Beyond the specific case, what is relevant is that this type of control responds to the automated information cross-checking scheme between electronic invoicing and the data reported in TRIBU-CR, an audit model that was established during his administration at the Ministry.
Beyond the specific case, the statement evidences something technical: the detection does not arise from a traditional identification process, but from the automated cross-check between electronic invoicing and tax returns within TRIBU-CR.
Today, the Administration can identify atypical patterns such as:
i. Companies with high invoiced amounts but without a coherent operating structure.
ii. Taxpayers using significant expenses coming from the same supplier.
iii. Unusually low margins compared to the sector.
iv. Purchases that are not consistent with the registered economic activity.
Tax auditing is no longer reactive; it is predictive.
Media News such as El Financiero have pointed out that fiscal closing 2025 arrives with a greater level of digital control, in an environment where the Administration has strengthened its data analytics and risk management tools. In this context, February and March became critical months: this is when the Administration profiles taxpayers before the March due date. Cross-checks between VAT, income tax, and electronic invoicing make it possible to detect companies that, even while formally complying with their filings, present results lacking coherence.
The Influence of the OECD Standard
This approach also responds to the international trend promoted by the OECD, where analysis by economic risk and coherence between activity and profitability are pillars of modern tax control. Pillar 2. The model no longer focuses on verifying isolated documents, but rather on evaluating whether the taxpayer’s financial structure is consistent with its operation.
The change is not regulatory; it is methodological. Today, a company may have technically correct accounting and still become subject to audit if its figures are not coherent with its economic reality.
The integration among electronic invoicing, D-270, and TRIBU-CR allows the Administration to analyze financial patterns without the need for an initial on-site audit. First, the risk is identified; then, an explanation is requested.
In this environment, tax compliance requires more than filing correctly: it requires being able to economically justify the results.
References
General Directorate of Taxation — Implementation of form D-270 through TRIBU-CR.
TRIBU-CR platform and fiscal closing for period 2025.
Economic publications on the strengthening of tax analytics (El Financiero, February 2026).
Public statements on the detection of invoice selling through electronic cross-checks (television interview, February 2026).
OECD — Administrative Guidance Pillar Two (2026).