Costa Rica

Corporate taxation

Corporate income is taxed at a 30% rate. However, special regulations apply for small companies whose gross income does not exceed 109,032,000 Costa Rican colones.

The Costa Rican tax system is based on the principle of territoriality, according to which any business activity in Costa Rica is subject to income taxation on local income in the same way as a registered business, irrespective of the place of incorporation. Such corporations doing business in Costa Rica are subject to the permanent establishment (PE) rules. Under the Costa Rican Income Tax Law, income from transactions carried out abroad may be regarded as non-Costa Rican-source income and then not subject to income taxes.

Transfer pricing

Previously Transfer Pricing in Costa Rico was based on Interpretative Guideline 20-03.

In 2013 the Costa Rican government published Decree N ° 37898-H, which established the transfer pricing guidelines for Costa Rican taxpayers. In 2019 a new Decree was issued N ° 41818-H.

In 2016, the Directorate General of Taxation published, by Resolution No. DGT-R-44-2016, the local Transfer Pricing Documentation requirements.

Links

Transfer Pricing Case Law

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