Data points
- Revenue floor below which the master file and local file are not required[1]
- No threshold
- Business days to produce both files once the tax office asks[1]
- 10 days
- Informative return deadline for the 2025 financial year[3]
- Oct 15, 2026
- Informative return deadline for the 2024 financial year[4]
- Nov 30, 2025
- General fine on prior year gross income, applied in place of a documentation penalty[1]
- 2%
- After the period end, to file the country by country report[1]
- 12 months
- When Costa Rica joined the OECD, as its 38th member[1]
- May 25, 2021
Costa Rica has no threshold. A Costa Rican entity with any related party transaction owes a master file and a local file, and the size of that transaction does not change the answer.
The four facts to know:
- A master file and a local file are required from every taxpayer with related party transactions. No revenue threshold and no exemption.
- Neither is filed. Both are kept, and produced within 10 business days of a request from the tax office, in Spanish.
- The one item on a calendar is the transfer pricing informative return. For the 2025 financial year it is due 15 October 2026, moved once from 30 September.
- There is no documentation penalty of its own. The general one is 2% of prior year gross income, floored and capped in base salaries.
Do I need a master file and local file in Costa Rica?
Yes, if your Costa Rican entity transacts with a related party at all. Both documents are required with no revenue floor and no exemption, so a small subsidiary owes the same two files as a large one. The OECD country profile for Costa Rica[1] records both positions.
That is a real difference from most of Latin America and from Europe, where a master file sits behind a consolidated revenue bar. In Costa Rica the question is never how big the dealings were. It is only whether there were any. Both files follow the standard international template, so the group's existing master file is usually the right starting point once it is translated.
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| Question | Answer | Source |
|---|---|---|
| Who must document? | Any Costa Rican taxpayer with related party transactions | OECD |
| What triggers it? | Related party transactions. No revenue threshold and no exemption | OECD |
| When is it due? | Kept, not filed. Produced within 10 business days of a tax office request | OECD |
| What is the penalty? | No documentation penalty of its own. The general one is 2% of prior year gross income | OECD |
When are the master file and local file due in Costa Rica?
They have no due date. Both are held and produced within 10 business days once the tax office asks for them in a control action. Everything handed over is in Spanish.
So the Costa Rica filing deadline for a master file is a trick question: there is not one. The deadline that matters is the 10 business day clock that starts the moment an auditor writes to you, and it is short enough that a file begun on day one will not be finished on day ten.
What language must the documentation be in?
Spanish. The master file and the local file are delivered in Spanish, which means a group master file drafted in English still needs a Spanish version before it can satisfy a request. No language limit is recorded for the country by country report, although Spanish is the official language. Translating after the request arrives is what turns a 10 day window into a missed one.
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What is Costa Rica's transfer pricing informative return?
It is the one transfer pricing item filed on a calendar, submitted through the tax office's online platform. The standing rule is filing within six months of the close of the financial year. The return was reintroduced in July 2025[2] and amended later the same year.
Under the six month rule the 2025 financial year return fell due on 30 September 2026. It was moved once, to 15 October 2026[3], after the filing platform went down on the original date, and no sanctions apply to anyone who filed by the new date. The 2024 financial year return was due on 30 November 2025[4].
Who exactly has to file the return is not confirmed from a final primary source. A consultation draft and secondary summaries describe the filers as large national taxpayers, free zone companies, and taxpayers with related party transactions above 1,000 base salaries. That scope has not been confirmed in a published final text, so this page flags it rather than stating it.
Does Costa Rica require country by country reporting?
Yes, and it is due 12 months after the end of the financial period. The revenue threshold behind it is not confirmed from a current primary source, and neither are the notification mechanics.
The commonly quoted EUR 750 million consolidated revenue bar and a March notification date come from a 2018 resolution[5], but the current country profile does not restate them. Confirm both with your Costa Rican adviser before you rely on a number from elsewhere.
What are Costa Rica's transfer pricing deadlines for 2026?
The dates split into two kinds: documentation produced on request, and the one return filed on a calendar. Each row below carries the year it applies to.
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| Obligation | Deadline | Year it applies to | Source |
|---|---|---|---|
| Master file | Within 10 business days of a tax office request | Any open year | OECD |
| Local file | Within 10 business days of a tax office request | Any open year | OECD |
| Country by country report | 12 months after the end of the financial period | Any open year | OECD |
| Transfer pricing informative return | 30 November 2025 | 2024 financial year | Ministerio de Hacienda, Costa Rica |
| Transfer pricing informative return | 15 October 2026, moved once from 30 September 2026 | 2025 financial year | Ministerio de Hacienda, Costa Rica |
What are the penalties for getting Costa Rica transfer pricing wrong?
There is no transfer pricing penalty. The general tax code fine applies instead: 2% of prior year gross income, with a minimum and a maximum both expressed in base salaries. For most subsidiaries that lands well below the real exposure.
The real exposure is the adjustment. With the master file and the local file missing or thin, the tax office can restate the Costa Rican entity's taxable income against the arm's length standard, and the documentation is the only defence against that. The defence has to exist on the day the request arrives, not be started then.
How closely does Costa Rica follow the OECD guidelines?
Closely. Costa Rica joined the OECD on 25 May 2021 as its 38th member and is an Inclusive Framework member. It applies the five OECD methods and both documentation files follow the international template.
The Guidelines are not written into Costa Rican law. They are used as guidance, and the comparability chapter is largely followed. For a parent that already runs OECD aligned documentation, Costa Rica is a low surprise jurisdiction. The surprise is the 10 day clock and the Spanish, not the economics.
What is still not confirmed for Costa Rica in 2026?
Five things cannot be stated as current fact from a primary source. This page flags each rather than guessing, because a wrong threshold is worse than a missing one.
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| Field | Status | What would confirm it |
|---|---|---|
| Country by country reporting threshold | Not confirmed | A current tax office resolution, or the refreshed OECD country profile, restating the figure |
| Country by country notification | Not confirmed | A current resolution confirming the notification date and method |
| Informative return filer scope | Not confirmed | The final published text of the 2025 resolution |
| Benchmarking refresh cadence | Not confirmed | A regulation setting how often comparables must be updated |
| Statute of limitations | Not confirmed | The tax code provision quoted with its current period |
The OECD refreshed Costa Rica's country profile in January 2026, and the text this page could reach dates to July 2021, so the master file, local file and country by country answers carry that caveat.
How we help with Costa Rica transfer pricing
Costa Rica gives you 10 business days to produce a Spanish master file and local file once the tax office knocks, and no threshold below which you can skip either. We build the benchmarking and the functional analysis, draft both files in Spanish, keep them current year by year, and file the informative return on its date. See how our transfer pricing software works.
Book a demo to get a Costa Rica documentation readiness check before the next informative return date.
Official sources
5 sources
- 1.OECD. Transfer pricing country profile: Costa Rica
- 2.Imprenta Nacional, Costa Rica. Resolution MH-DGT-RES-0026-2025 of 10 July 2025 on the transfer pricing informative return
- 3.Ministerio de Hacienda, Costa Rica. Resolution MH-DGT-RES-0030-2026 moving the informative return deadline to 15 October 2026
- 4.Ministerio de Hacienda, Costa Rica. Resolution MH-DGT-RES-0043-2025 setting the 2024 informative return deadline
- 5.Imprenta Nacional, Costa Rica. Resolution DGT-R-001-2018 on country by country reporting
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
