Transfer Pricing Rules in Costa Rica

The new rules governing prices agreed by two companies when transfering goods, services or rights between them are now in force.

Friday, September 13, 2013

"The new rules will fill a legal vacuum which created uncertainty for taxpayers and will satisfy a requirement of the tax administration in light of operations of multinational companies", noted an article in

The decree published in the official newspaper says the aim of this new legislation is to "provide greater legal certainty, both to the taxpayer and the tax authorities."

It also establishes powers for the tax administration among which are the methods for comparing prices and the documents which must be held by taxpayers.

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More on this topic

How FDI Affects Transfer Pricing Rules

September 2013

In order for transfer pricing rules not to affect foreign investment, double taxation should be prevented.

According to Jose Antonio Saborio in his article in, it is not that transfer pricing rules (NPT) scare off foreign investment, "... rather they provide greater security to multinationals interested in investing, especially if the country has an extensive network of agreements to prevent or minimize double taxation (DII), which will allow two or more countries to discuss their differences on NPT, when the application of the latter leads to DII ".

Transfer Pricing in Costa Rica

July 2013

The regulation currently being processed aims to regulate the sale prices of goods and services between related companies.

"... the Executive power has introduced a bill, which is being processed by the legislation, called the Law on Control of Fiscal Evasion, which includes a chapter on this subject, which is virtually a decree, with the addition of specific sanctions for breaches of duties set out in the bill," says Ana Elena Carazo in

Costa Rica: Preparing for Transfer Pricing Rules

June 2013

The General Directorate of Taxation is preparing regulations to govern the sales prices of goods and services between companies considered as related to each other.

This regulation is currently under review by the legal department of the Ministry of Finance. The aim is to have it in force before the end of the current administration, said Carlos Vargas, CEO of Taxation.

Panama: Transfer Pricing Forum

February 2013

Analysis of the new requirement by the Department of Revenue, which requires taxpayers to report transactions with related companies.

A statement from the Chamber of Commerce, Industries and Agriculture of Panama (CCIAP) reads:

Wednesday 27 February
The Center for Economic Studies at the Chamber of Commerce, Industries and Agriculture of Panama will hold a Forum on Transfer Pricing Reports: Analysis and Impact