Transfer Pricing

Transfer Pricing

The continuous modifications and innovations in Transfer Pricing at a global level have a direct impact in Costa Rica, posing a series of important challenges for companies in relation not only to formal duties and obligations, but especially to the need to have a strategic vision of their structure and operation, according to the market prices that should prevail in their operations with related entities.

On the other hand, the development, implementation and control of Transfer Pricing by the Tax Administration has undergone a rapid evolution that has been accompanied by a dizzying increase in the formal obligations of taxpayers, in the levels of access to national and international information, as well as a significant increase in litigation on the subject.

Our firm has experienced professionals of high technical and academic level, committed to serve transnational companies in several of the most relevant cases of Transfer Pricing at the national level, which are constantly updated on any new guidelines and criteria issued by the ODCE, local rules and regulations, as well as jurisprudence both in administrative, judicial and constitutional headquarters.

  • Transfer Pricing Studies: Preparation of annual reports on market value compliance of transactions with related companies, such as Local File (Transfer Pricing Study), Master File and Country by Country Report.
  • Planning: Analysis in perspective to define the treatment of future transactions. Advice on documentation requirements and best international practices. Review of Transfer Pricing Manuals of the companies and their coverage in the compliance with local regulations.
  • Previous valuation agreements: Assistance and negotiation of previous valuation agreements with the Tax Administration.
  • Conflict resolution: Defense and legal representation in litigious processes related to the Transfer Pricing issue.


Alfredo Rodríguez



Diego Martín


El Salvador

Armando Manzanares



Carlos Taboada



Rafael Luna


Costa Rica

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