New way of auditing in Costa Rica: The Treasury validates financial consistency before reviewing accounting records

By Gabriela Páez

The fiscal year-end for 2025, for which the tax return must be filed in March 2026, is revealing a significant shift in how the Tax Administration selects taxpayers for audits. It's no longer just about accounting errors or arithmetic discrepancies; the new approach is based on the economic consistency of the business.

Simply put: if the numbers don't "match" with the business's economic activity, the audit begins.

This change is not accidental; it stems from the technological integration between TRIBU-CR, electronic invoicing, and the new monthly information returns, which allows the Tax Administration to analyze each taxpayer's financial behavior in near real-time. Under this model, the tax authority not only reviews declared data but also compares that information with sectoral patterns and comparable economic parameters, applying economic reality and benchmarking analyses.

One of the most relevant changes was the replacement of the annual information return D-151 with the monthly form D-270, which requires monthly reporting of customer and supplier information.

This form serves a key function: to record deductible expenses that do not have a national electronic invoice. According to the clarification issued by the Tax Administration, these may include:

• Payments to the CCSS

• Municipal taxes

• Payments to State institutions

• Bank interest

• Transfer fees

• Commissions for the use of card payment terminals

• Other financial or institutional charges

In practice, any domestic expense that is intended to be deducted and that is not supported by an electronic receipt must be reported through this information return.

This change means that the Tax Administration no longer needs to wait until the end of the fiscal year to understand a taxpayer's business structure. The information is received and analyzed monthly. It's important to note that this report does not replace the lack of an electronic receipt when one is required under current regulations.

Additionally, the reporting of remittances abroad expands the ability to monitor payments to foreign suppliers, royalties, technical services, interest, and other international expenditures. This allows the tax authorities to compare payments made with applicable withholdings and the economic nature of the transaction.

Massive cross-referencing of information

Currently, the Tax Administration can automatically cross-reference various sources of information, including:

a) Electronic receipts issued and received

b) VAT returns

c) Informative D-270

d) Withholding taxes

e) Declarations of remittances abroad

f) Income tax return

If sales recorded through electronic invoicing are not related to the declared profit or the reported expense structure, the system can quickly detect inconsistencies.

What has been publicly stated: selling invoices and cross-platform trading

Recently, in a television interview, the former Minister of Finance and current elected deputy, Nogui Acosta, indicated that the Tax Administration detected a company dedicated to issuing invoices for approximately ₡50 billion to fraudulent taxpayers, who used these receipts to artificially reduce their tax burden.

According to reports, the Administration will prosecute both those who issued the invoices and those who used them.

Beyond the specific case, what is relevant from a technical point of view is the detection mechanism: automated cross-referencing between electronic invoicing, tax returns and the TRIBU-CR platform.

Today, the Tax Administration, with this type of analysis, can identify atypical patterns such as:

• Companies with high invoiced amounts but without a coherent operational structure.

• Taxpayers who use significant expenses from the same supplier, or related companies.

• Profit margins significantly lower than those of the economic sector.

• Purchases that are not related to the registered economic activity.

In this context, oversight ceases to be reactive and becomes predictive.

What El Financiero published and the context of the fiscal year-end

Various journalistic analyses, such as those published by El Financiero, have indicated that the 2025 fiscal year-end will bring a greater level of digital control, in an environment where the Administration has strengthened its data analysis and risk management tools.

In this context, the period prior to the March deadline becomes particularly relevant, as this is when the Tax Administration profiles taxpayers by cross-referencing:

• VAT returns

• Income Tax Return

• Electronic invoicing

• Informative statements

This allows the detection of companies that, even while formally complying with their reporting obligations, present results that do not reflect economic consistency.

Influence of international standards

This approach also aligns with international trends driven by the OECD, where modern tax control models prioritize economic risk analysis and the consistency between activity and profitability as pillars of modern tax control. Pillar 2.

The model no longer focuses on verifying isolated documents; it now assesses whether the taxpayer's financial structure is consistent with its operations.

The change facing the Costa Rican tax system is not only regulatory, but also methodological.

Today, a company can have technically correct accounting and still be subject to audit if its figures do not reflect consistency with its economic reality.

The integration of electronic invoicing, information returns, and the TRIBU-CR platform allows the Tax Administration to identify tax risks through data analysis. This cross-referencing of information strengthens the Administration's ability to initiate control measures, such as abbreviated or formal audits, and even issue preliminary assessments, before initiating a full tax audit.

In this environment, tax compliance requires more than just filing correct returns: it requires being able to explain the business results economically.

References

• General Directorate of Taxation — Implementation of form D-270 through TRIBU-CR.

• TRIBU-CR platform and fiscal year-end 2025.

• Economic publications on strengthening tax analytics (El Financiero, February 2026).

• Public statements on detecting invoice sales through electronic cross-referencing (television interview, February 2026).

• OECD — Administrative Guidance Pillar Two (2026).