Oct 6, 2025
Regulatory framework
Until July of this year, through Resolution MH-DGT-RES-0026-2025, it had been established that large taxpayers, companies under the free trade zone regime, and those taxpayers with related-party transactions that together exceed 1,000 base salaries were required to file a transfer pricing informative return. The initial deadline set for the 2024 fiscal period was November 30, 2025, using as the only means the new TRIBU-CR platform, which will officially begin operating on October 6.
The new resolution issued in September modifies this scenario and grants companies a breather, moving the deadline to March 31, 2026. The change seeks to facilitate the transition to TRIBU-CR and to provide enough time for taxpayers to prepare the necessary technical documentation. In practice, the Tax Administration recognizes that implementing a digital system of this magnitude requires an adaptation period, especially in a complex matter such as transfer pricing.
However, this extension should not be interpreted as a relaxation of enforcement. On the contrary, the Tax Administration has been strengthening its control capabilities in line with OECD standards. The deadline is extended, but the expectation regarding the quality of studies and the information reported remains the same. For companies, this means the need to have solid comparable analyses, properly applied valuation methods, and supporting documentation that can withstand any future review.
Practical implications
· Importance of the TRIBU-CR platform: all filing must be done through this system; submissions through other channels will be considered invalid or not filed.
· Reinforcement of the arm’s length principle: the informative return serves for the General Directorate of Taxation to verify whether related-party transactions were carried out under terms that independent parties would have agreed upon.
Conclusion
Resolution MH-DGT-RES-0043-2025 represents an important adjustment in Costa Rica’s tax regime, granting an additional deadline for the 2024 fiscal year Transfer Pricing Informative Return, while consolidating the obligation introduced in Resolution MH-DGT-RES-0026-2025. Although this extension provides more time, companies subject to this requirement must use this period to ensure their documentation is in order, their studies are up to date, and their electronic filings ready.
Official references
· Resolution MH-DGT-RES-0026-2025, “Resolution regarding the filing of the Informative Return in the matter of transfer pricing.”
· Resolution MH-DGT-RES-0043-2025, “Amendments to the General Resolutions that implement various functionalities and forms within the Integrated Tax Management System known as TRIBU-CR.”
· Portal of the Ministry of Finance / General Directorate of Taxation – information on TRIBU-CR and tax obligations.