Transfer pricing
In an increasingly globalized business environment, Costa Rican companies within multinational groups must ensure that transactions between related parties occur at market prices. Our Transfer Pricing services help you comply with local regulations (aligned with OECD guidelines) and international obligations, minimizing risks and avoiding penalties. A correct transfer-pricing strategy guarantees compliance before tax authorities and protects your company from tax adjustments in potential audits and inspections.
We have a leading team in this field (part of the global HLB network) that will provide expert support at every step, from planning to defending your transfer-pricing policies.
Services in Transfer Pricing:
Transfer-Pricing Study: Preparation of the technical documentation that analyzes and substantiates that your intercompany transactions comply with the arm’s-length principle under Costa Rican regulations.
Benchmarking (Comparable Analysis): Market research and use of international databases to identify comparable transactions and determine appropriate margins.
Obligation Diagnostics: Initial evaluation to determine if your company is required to comply with transfer-pricing regulations, based on transaction volume and criteria set by tax authorities.
Master File Preparation: Compilation and structuring of the group-level Master File, documenting your global economic group’s information in line with BEPS requirements and the Costa Rican Tax Administration.
BEPS 13 Compliance (Country by Country Report): Guidance in preparing and submitting the Country-by-Country Report, meeting the BEPS Action 13 standard for reporting your group’s global distribution of revenue, taxes and economic activities.
Multijurisdictional Filings: Coordination and support for transfer-pricing disclosures in Costa Rica and other jurisdictions where your company operates, leveraging HLB’s international presence.
Audit & Litigation Support: Expert assistance in case of audits, adjustments or disputes related to transfer pricing, including technical defense before the Tax Administration and support in appeals or judicial proceedings.
