Nov 10, 2025
Evolution of Transfer Pricing Documentation and the DGT’s Smart Audit Model
1. TRIBU-CR: A Unified and Traceable Platform
TRIBU-CR replaces the former ATV portal and consolidates tax administration into eight core modules: Virtual Office (OVI), Returns and Payments, Integrated Tax Account, Taxpayer Registry (RUT), Communications and Notifications, Hacendary Inquiry, Electronic File, and Document Manager.
Each taxpayer now has a comprehensive electronic profile, including all filings, payments, notices, withholdings, and historical transactions. This integrated view strengthens traceability and facilitates faster responses to both taxpayer inquiries and DGT audits.
One of the most relevant developments is the Integrated Tax Account, providing real-time visibility of balances, credits, and liabilities. Notifications and formal communications are handled electronically, under a 24/7 citizen-centered model that simplifies compliance and improves accessibility.
According to the Ministry of Finance, “TRIBU-CR will modernize tax management nationwide, bringing tangible benefits to taxpayers through automation and transparency.”
2. Transfer Pricing Documentation: A New Compliance Phase
Resolution MH-DGT-RES-0026-2025 introduces a renewed transfer pricing information obligation to be filed exclusively through TRIBU-CR.
Taxpayers subject to filing include:
Large taxpayers and companies operating under the Free Trade Zone Regime with local or cross-border related-party transactions.
Any taxpayer whose transactions with related parties exceed ₡462,200,000 (1,000 base salaries) during the fiscal year.
Filing deadlines:
For fiscal year 2024, the first information return must be filed no later than November 30, 2025.
In subsequent periods, the standard deadline will be six months after the fiscal year-end.
The new electronic form will be pre-validated by the system and automatically incorporated into the taxpayer’s digital file. This enables the DGT to cross-check transfer pricing data against income tax filings, electronic invoices, and accounting records, ensuring consistency across systems.
3. Smart Audit and Automated Data Cross-Validation
With TRIBU-CR, Costa Rica enters the era of real-time digital tax control. The platform interconnects multiple data sources — electronic invoicing, VAT and income tax filings, the RUT, and transfer pricing information — to detect inconsistencies between reported and actual financial data.
The DGT’s audit approach is now based on automated risk analysis, leveraging algorithms to identify unusual patterns or discrepancies between taxpayer filings and third-party reports. As the Ministry of Finance emphasizes, “every transaction and action is recorded for future reference.”
TRIBU-CR also interfaces with Customs, the CCSS, SUGEF, and the Central Bank, enabling the cross-validation of import data, payroll information, and financial movements. This integration allows the Administration to focus its audit resources on high-risk operations, while routine, low-risk taxpayers benefit from simplified oversight.
4. Transparency and Alignment with International Standards
TRIBU-CR’s design is fully consistent with the BEPS Action 13 recommendations and the OECD Transfer Pricing Guidelines, which promote standardized reporting and information exchange among jurisdictions.
Although Costa Rica is not yet a full OECD member, it has adopted these principles as a reference for its local framework. The digital ecosystem reinforces transparency, traceability, and comparability, essential attributes for a modern tax system.
The DGT’s objective is to transition from reactive enforcement to predictive, data-driven risk management, positioning Costa Rica as a regional benchmark in digital tax governance.
5. EAS LATAM Recommendations Ahead of FY-2025 Close
Given the magnitude of these changes, companies should proactively prepare to operate within this new digital compliance environment:
Update taxpayer registration (RUT) and contact information before the migration to ensure accurate electronic communication.
Adopt version 4.4 of the electronic invoicing system, effective since September 2025, to guarantee data compatibility with TRIBU-CR.
Maintain synchronized accounting and tax records to prevent inconsistencies within the electronic file.
Prepare or update the transfer pricing study following the arm’s-length principle; ensure data aligns with accounting and invoicing records.
Train finance and tax teams on the new TRIBU-CR modules, workflows, and digital submission protocols.
Leverage the Integrated Tax Account to monitor balances, withholdings, and credits in real time.
Costa Rica’s tax administration is transitioning toward a continuous, data-driven audit model, where transparency and consistency define compliance.
The implementation of TRIBU-CR and the reinstatement of the transfer pricing information obligation represent a maturing fiscal framework — one that prioritizes proactive risk management, technological integration, and legal certainty.
For both local and multinational groups, the imperative is clear: align financial reporting, tax documentation, and transfer pricing disclosures within a unified digital ecosystem, anticipating the DGT’s new verification capabilities.
Technology has become the language of compliance in Costa Rica — and TRIBU-CR, its cornerstone platform.
Sources:
Costa Rican Ministry of Finance, Resolution MH-DGT-RES-0026-2025; official communications on Hacienda Digital and TRIBU-CR implementation.