Costa Rica adopted the OECD BEPS Action 13 framework in 2017 and issued its formal CbCR rules in 2018, committing to information exchange and multilateral implementation.

Legal & Regulatory Framework

• Legal Basis: Resolution DGT‑R‑001‑2018, gazetted on 2 February 2018
• Requires CbCR, Master File, and Local File documentation (Master & Local File under Resolution DGT‑R‑16‑2017)
• Threshold: global annual revenues ≥ ₡435,771,852,750 (approx. 750 million EUR).

Who Must File

• Ultimate Parent Entity (UPE) resident in Costa Rica if group revenue exceeds threshold.
• Surrogate Parent Entity (SPE) resident domestically, if UPE isn’t obligated to file or jurisdiction lacks exchange agreement
• No CbCR obligation if the UPE files abroad and reports are exchanged with Costa Rica

Notification Requirements

• All Costa‑Rican constituent entities must notify the tax authority by the last business day in March each year
• Notification must include UPE or SPE details via digital form signed by legal representative

CbC Report Filing

• Deadline: By 31 December of the year after the reporting fiscal year (e.g., FY 2023 → file by 31 December 2024)
• Submission is annual and follows one-year retrospective deadline.

Content of the Report

• Per-jurisdiction data: revenue (related/unrelated), pre-tax profit/loss, income tax paid/accrued, stated capital, retained earnings, headcount, tangible assets, and list of constituent entities with activities .
• Must be prepared in Spanish; in case of discrepancy, the Spanish version prevails

Penalties for Non‑Compliance

• Fines up to CRC 5 million (≈ USD 8,000) for non-filing, late submission, or inaccurate content

Exchange & Use of Reports

• Costa Rica signed the OECD MCAA in January 2016; began receiving CbC information from other jurisdictions as of 2024
• Peer reviews (2024) indicate full implementation of CbCR, confidentiality, and exchange standards

Key Considerations

• Ensure notification and CbC filings are made on time to avoid penalties.
• Maintain Master File and Local File as per transfer pricing rules.
• Use consistency between your CbC report and Spanish financial documentation.
• Stay updated on evolving OECD guidance and local legislative amendments

Useful Resources

• Dirección General de Tributación (Costa Rica) – Resolution DGT‑R‑001‑2018 official gazette.