For years, Declaration D-151 was a common tool in tax compliance in Costa Rica. Its purpose was clear: to supply the Tax Administration with relevant information about economic relationships between taxpayers.
However, with the consolidation of electronic invoicing, many assumed that these types of informational statements were a thing of the past.
Except for the reporting for taxpayers in the simplified regime, for which a system has even been implemented where a valid receipt before the Tax Administration was issued through electronic purchase invoices.
The logic seemed reasonable. If every relevant transaction had to be supported by an electronic voucher validated by the Tax Agency, the system itself would be responsible for capturing and centralizing the necessary information for control and auditing purposes.
In that context, the D-151 lost the prominence it had at each period close.
But the story didn't end there
With Resolution No. MH-DGT-RES-0055-2025, the Tax Administration reintroduces the concept under a new figure: Informative Declaration 270 (D-270).
Although it formally replaces the D-151, its essence is the same: to capture information about economic relationships that are not recorded within the electronic voucher system.
In other words, the information didn't disappear; it simply evolved.
However, its return is not without complications. The initial wording of the resolution led many to interpret that D-270 had a broad, almost residual scope: to report anything not covered by electronic invoicing.
This reading, although defensible from a literal standpoint, generated an immediate effect in practice: over-reporting, unnecessary operational burdens, and an increase in technical uncertainty.
Tax Administration Intervention
Faced with this scenario, the Tax Administration intervened. First, through communication CP-09-2026, it clarified that the D-270 should not be understood as a general declaration, but rather as a tool aimed at specific cases.
Subsequently, with Resolution No. MH-DGT-RES-0010-2026, it introduced regulatory adjustments that extended deadlines, established a transitional regime without penalties, and clarified the legal scope of the obligation.
The message, while progressive, was clear: D-270 does not seek to capture everything that was left out of electronic invoicing, but only certain areas where the system does not have full coverage.
Among these are highlighted, mainly, professional services, rentals, interest and commissions not subject to VAT, certain operations with the public sector, and specific financial system registrations.
In other words, areas where, by design or by regulatory exception, there is no electronic receipt that allows the Tax Agency to obtain information automatically.
The true role of the D-270
This allows for a better understanding of the true role of D-270 within the current tax ecosystem. It's not a substitute for electronic invoices, nor an extension of them. It's a complement.
A closing mechanism for transactions that, by their nature, fall outside the main recording circuit.
The comparison with the D-151 is inevitable. Both meet the same need for information. The difference lies in the technological context.
While the D-151 operated in an environment where information was more dispersed, the D-270 is inserted into a digitized system, where most operations are already captured in real time.
That's why your application demands greater precision
In this new environment, the risk is not limited solely to omitting information, but also to a lack of clarity about what should be reported in certain cases.
Faced with this uncertainty, it is reasonable to adopt a conservative stance that favors the supply of information when in doubt, as it is a formal duty whose scope is still being practically defined.
The lesson is clear: the D-270 does not revive the logic of the D-151 in its original form. It adapts it.
The informative notice, in effect, has not gone out of style. But its use today is more surgical than general. It requires technical judgment, understanding of the system, and, above all, an integrated reading between the regulation and the administrative criteria that accompany it.
It is fundamental that taxpayers carefully review the information they are reporting, or not reporting, on the D-270 Informative Declaration, especially considering that its scope continues to be refined through administrative criteria and regulatory adjustments.
It is advisable to keep in mind the transitional provisions introduced by the Tax Administration. Among them, it was established that the declaration for the 2025 period may be filed until June 2026.
Additionally, until January 25, 2027, declarations corresponding to the periods of January 2026 to December 2026, including omitted or amended declarations, may be submitted without the application of fines or penalties associated with said transitional periods.
An opportunity
In practice, this scenario also presents an opportunity for taxpayers to review and update how they are obtaining and debugging information from their accounting systems, especially for operations not supported by electronic invoices.
Furthermore, even those taxpayers who already have adequate internal mechanisms for data extraction and validation could opt to file monthly without any issues.
In formal obligations of this nature, the technical review of information and the adaptation of internal processes continue to be one of the main tools for ensuring adequate tax compliance.
Because in current tax practice, complying correctly means reporting better, even if it means adopting a cautious stance in case of doubt while the Tax Administration's criteria are consolidated.