Transfer Pricing
Specialized services in transfer pricing in Costa Rica. Technical studies, informative declaration, defense before DGT and OECD compliance. 30+ years of experience.
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Tidying up the house: key to growth
Pay the taxes determined by law, no more and no less.
Ready for the three visits
We help you to prepare your company for the visit of the authorities, the visit of a potential buyer and for an orderly succession.
Creative solutions
Thinking "out of the box" is part of our identity.
Leading Post-OECD Compliance Specialists
ICS Consultores is the leading firm in Costa Rica in transfer pricing services, with extensive experience and under the direction of Francisco Villalobos, former Director General of Taxation of Costa Rica. We offer comprehensive solutions to ensure compliance with the new regulations derived from Costa Rica's membership in the OECD.
Transfer Pricing Studies
Complete technical studies under OECD methodology
- Detailed functional analysis (functions, assets and risks)
- Application of the 5 methods approved by the OECD
- Benchmarking with specialized databases Capital IQ from S&P and Royaltystat
- Selection and technical justification of the most appropriate method
- Support documentation for DGT audits
- Annual update according to regulatory changes
Deliverables:
- Complete technical study (80-150 pages average)
- Executive summary for management
- Annual update schedule
- Archive of supporting documentation
Mandatory Informative Statement
Compliance with the new 2025 obligation
- Preparation and filing of annual information return
- Applicability analysis according to thresholds and DGT criteria
- Collection and validation of required information
- Interface with Treasury's TRIBU-CR system
- Follow-up of deadlines according to fiscal closing
- Management of subsequent corrections or clarifications
Coverage:
- Large National Taxpayers Category A
- Entities under the free trade zone regime with related operations
- Companies whose shareholders or directors are classified as Large Taxpayers
- Taxpayers that carry out transactions with related parties whose total amount exceeds 1,000 base salaries during the tax period
Master File and Local File
Documentation according to BEPS standards Action 13
- Master File: Multinational group documentation
- Local File: Costa Rican entity specific information
- Preparation in Spanish according to DGT requirements
- Integration with country-by-country reporting (CbCR)
- Maintenance and annual update
- Coordination with other jurisdictions in the group
Applicable for:
- Multinational groups with revenues >€750 million
- Entities with significant related party transactions
- Companies in the process of international expansion
Defense before DGT Audits
Specialized representation in audits
- Preparation prior to audits by the General Tax Directorate (DGT)
- Technical representation before DGT officials
- Preparation of pleadings and additional documentation
- Preparation of appeals and revocation appeals related to the administrative process.
- Subsequent risk analysis and preventive measures
Competitive advantages:
- Preventive approach to audits
- Comprehensive end-to-end representation
- Significant reduction of audit time
Advance Pricing Agreements (APA)
Legal certainty for complex methodologies
- Feasibility assessment for unilateral PACs
- Preparation of specialized technical documentation
- Management of the process before DGT
- Negotiation of terms and conditions
- Compliance monitoring during the term
- Renewal at maturity (up to 5 years)
Ideal cases:
- Transactions with unique intangibles
- Complex financial structures
- Specialized intragroup services
- Multi-jurisdictional operations
Strategic Transfer Pricing Consultancy
Optimization of operational and fiscal structures
- Transfer pricing policy design
- Analysis of corporate restructurings
- Due diligence in M&A transactions
- Implementation of shared service centers
- Tax risk assessment by country
- Training for internal teams
Consultation with Our Attorneys
ICS Consultores stands out for offering comprehensive legal advice and customized solutions in Costa Rica. Our team of expert lawyers is ready to help you with all your legal needs, from litigation and contracts to conflict resolution. Trust us to provide you with a high quality legal service tailored to your needs.
Work Process
Phase 1: Diagnosis
2-3 weeks
The diagnostic phase lays the foundation for the project through a thorough analysis of the company's current situation. During this period, our team conducts strategic interviews, assesses existing risks and designs a customized roadmap that will guide the entire transfer pricing compliance process.
Interviews with management and operational team
Review of organizational structure and operations
Analysis of existing intercompany contracts
Assessment of current liabilities and risks
Technical proposal and detailed schedule
Phase 2: Technical Analysis
4-8 weeks
The heart of the project lies in this analytical phase, where the transfer pricing methodology is rigorously applied. Through comparable studies and specialized calculations, we determine the market ranges that will support intercompany transactions, ensuring that they comply with the arm's length principle.
Collection of detailed information
Complete functional analysis
Search and selection of comparables
Application of selected methodology
Calculation of market price ranges
Phase 3: Documentation
2-3 weeks
The documentation phase transforms the technical analysis into practical and defensible instruments before the tax authorities. We prepare the complete formal study, train the client's internal team and deliver all the necessary supporting documentation to guarantee the correct implementation and defense of the established prices.
Preparation of final technical study
Customer review and validation
Preparation of supporting documentation
Training for the customer's internal team
Phase 4: Implementation and Follow-up
2-3 weeks
This final phase ensures the long-term sustainability of the project through continuous support. We manage the filing of information returns, monitor regulatory changes and provide annual updates, keeping your transfer pricing structure always current and in compliance.
Filing of informative declaration
Monitoring of regulatory changes
Scheduled annual updates
Continuous support for queries
ICS Competitive Advantages
ICS stands out in the Costa Rican market for combining unique regulatory experience with state-of-the-art transfer pricing technology. Our proposal integrates internal knowledge of the criteria of the General Directorate of Taxation with international methodologies supported by the most advanced analytical platforms in the market, ensuring robust and defensible technical studies before any audit.
Unique Expertise in Costa Rica
ICS stands out in the Costa Rican market for combining unique regulatory experience with state-of-the-art transfer pricing technology. Our proposal integrates internal knowledge of the criteria of the General Directorate of Taxation with international methodologies supported by the most advanced analytical platforms in the market, ensuring robust and defensible technical studies before any audit.
Francisco VillalobosFormer General Director of Taxation
Internal knowledgeDGT Process and Criteria
Proven experience30+ years in international taxation
- Global network: Allinial Global in 98 countries
Technology and Processes
Our technological infrastructure combines the most prestigious databases in the market with specialized advanced statistical analysis software. Digitized processes guarantee efficient and accurate deliveries, while our collaborative platform provides clients with 24/7 access to all their transfer pricing documentation, ensuring transparency and full control over the project.
Access to premium databases: S&P Capital IQ and Royaltystat
Specialized software: Advanced statistical analysis
Digitized processes: Efficiency in service delivery
Collaborative platform: 24/7 access to documentation
Specialized Methodologies by Sector
Sectors of specialization
✓ Free Trade Zone: Manufacturing, services, distribution centers
✓ Technology: Software, telecommunications, digital services
✓ Financial Services: Banking, insurance, leasing
✓ Agriculture: Export, processing, marketing
✓ Retail and Distribution: Import, marketing, logistics
✓ Pharmaceuticals: Manufacturing, R&D, specialized distribution
✓ Energy: Generation, distribution, specialized services
Modalities of Service - Complete Transfer Pricing Study
We offer three flexible service modalities to suit the size and complexity of your operation. From medium-sized companies with few related transactions to multinational groups with complex global structures, each model is designed to ensure full regulatory compliance with the Directorate General of Taxation, including the preparation of the technical study, the mandatory informative declaration and the Master File and Local File documentation in accordance with OECD standards.
Medium-sized companies
Designed specifically for companies with simpler intercompany transactions, this model covers 1 to 3 types of linked transactions through analysis with one or two OECD methodologies. The deliverable includes all the basic documentation required by the DGT to comply with transfer pricing obligations, ensuring technical defense against possible audits without unnecessary complexity.
1-3 types of linked transactionsAnalysis with 1-2 OECD methodologiesBasic documentation requiredLarge companies
This comprehensive model serves companies with more complex and diversified intercompany transaction structures, covers multiple types of related-party transactions through a complete methodological analysis, and includes both the Master File and the Local File required by Costa Rican regulations, providing exhaustive documentation that accurately reflects the operating reality of the economic group and complies with the OECD's BEPS standards.
Multiple types of transactionsComplex methodological analysisMaster File and Local File includedMultinational groups
The most robust solution for multinational groups with presence in multiple jurisdictions and complex global operations. This service includes internationally coordinated multi-jurisdictional studies, complete BEPS documentation including Master File, Local File and Country-by-Country Report, ensuring consistency in transfer pricing policies globally and simultaneous compliance in all jurisdictions where the group operates.
Multi-jurisdictional studiesInternational coordinationComplete BEPS documentation
Next Steps
The engagement process is designed to be streamlined and transparent, with clearly defined steps from the first contact to the formal start of the project. In less than two weeks, your company can have a complete work plan, defined methodology and timeline in place to comply with all transfer pricing obligations before the DGT.
Contact usInitial contact:
Call or email to schedule consultation
Initial 30-minute no-obligation conversation
Preliminary review of corporate structure and related transactions
Identification of the most appropriate service modality
Explanation of regulatory requirements specific to your case
Diagnostic meeting:
Specific situation analysis
Detailed evaluation of existing intercompany transactions
Review of previous transfer pricing documentation (if any)
Identification of potential tax risks
Determination of project scope and applicable methodologies
Technical proposal:
Scope, methodology and schedule
Detailed technical proposal with specific OECD methodology
Work schedule with deliverables and key dates
Transparent quotation according to selected modality
Assignment of a specialized technical team for your project
Start of services:
Signing of the contract and kick-off meeting
Formalization of the professional services contract
Kick-off meeting with all the team involved
Definition of communication channels and points of contact
Initial information request and access to collaborative platform
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Business Trust Consulting in Costa Rica
✓ 30 years of experience
✓ Specialists in Costa Rican companies
Free Initial Consultation
Duration: 30 minutes
ICS Consultants
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