Transfer Pricing in Costa Rica

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

Wednesday, July 31, 2013

"... 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

This regulation aims to provide legal certainty for taxpayers and tax administration officials in relation to the actions of the supervisory bodies, who have been acting without any regulations to support them, "except for the Interpretive Guideline 20-03, 'Fiscal treatment of Transfer Pricing', which very generally empowers them to make adjustments based on this concept."

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Costa Rica: Tax Regulations Under Consultation

July 2016

Transfer pricing and double taxation are two of the topics covered in three bills to reform regulations which the Ministry of Finance has put to public consultation.

One of the proposals is the bill on "Informational declaration of transfer pricing". explains that   "...This empowers the tax authorities to check that transactions between related parties are valued at prices similar to those that would be agreed between independent parties in comparable transactions. " 

Honduras: Transfer Pricing Law Comes Into Effect

July 2015

It has been announced that in August the regulations governing transfer pricing will take effect and penalties will be imposed of $10 thousand to $20 thousand on companies that do not submit a declaration.

Companies that do not submit a declaration after three months after the entry into force of the regulations are subject to fines ranging between $10 thousand and $20 thousand.

Transfer Pricing Rules in Costa Rica

September 2013

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

"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

Transfer Pricing in Guatemala

December 2012

A new approved law aims to regulate transfer pricing, but detailed rules are still missing. reports that "In Guatemala the regulation of the transfer pricing has been approved as part of the tax update package, according 10-2012, to try to prevent related companies (parent and subsidiaries, for example) from manipulating prices when exchanging goods or services, so that they increase their costs or deductions in order to reduce taxes. "