The comment period runs from February 12, 2025 through Tuesday, February 25, 2025, both dates inclusive.
➢ The Resolution establishes that the filing of the transfer pricing statement will be annual.
➢ The declaration form will be available through the TRIBU-CR platform, ensuring a single means for the submission and receipt of declarations.
The Ministry of Finance has put out for public consultation the draft general resolution entitled "Resolution concerning the filing of the Informative Pricing Statement of Transfer".. This document establishes the obligation for certain taxpayers to to file an annual information return on its transactions with related parties, in compliance with Article 81 bis of the Income Tax Law and its regulations.
According to the draft resolution, the taxpayers required to file this return would be:
- Large domestic taxpayers that carry out domestic or cross-border transactions with related companies.
- Persons or entities under the free zone regime that carry out operations with related parties.
- Any profit taxpayer whose operations, separately or jointly, exceed the amount equivalent to 1,000 base salaries in the corresponding period.
The period for submitting comments on this project will be from February 12 to 25, 2025both dates inclusive. Comments should be sent in writing to the following e-mail address:
FiscaTecnicoJuridico@hacienda.go.cr.
In case of approval, the resolution will become effective after its publication in the Official Gazette La Gaceta. The informative declaration corresponding to the 2024 tax period must be filed six months after the entry into force of the resolution. For the following fiscal periods, the declaration must be filed within three months after the closing of the respective fiscal period.