Transfer Pricing

Transfer Pricing

“They are capable of effectively and creatively tackling complex problems.”
Client for chambers & Partners

Why us?

The continuous modifications and innovations in global Transfer Pricing have a direct impact on Costa Rica, posing a series of significant challenges for companies, not only in terms of formal duties and obligations but especially in the need to have a strategic vision of their structure and operation in line with prevailing market prices in their transactions with related entities.

Furthermore, the development, implementation, and oversight of Transfer Pricing by the Tax Administration have undergone rapid evolution, accompanied by a dizzying increase in formal obligations for taxpayers, levels of access to national and international information, as well as a significant rise in litigation in this area.

Our firm has highly experienced professionals with advanced technical and academic expertise, committed to serving multinational companies in several of the most relevant Transfer Pricing cases at the national level. They are constantly updated on any new guidelines and criteria issued by the OECD, local regulations and legislation, as well as administrative, judicial, and constitutional case law.


Our portfolio of services tailored to your regional business needs includes:

    • Transfer pricing studies: Preparation of annual reports on compliance with arm’s length prices for transactions with related parties, such as Local File (Transfer Pricing Study), Master File, and Country-by-Country Report.
    • Planning: Analysis from a forward-looking perspective to define the treatment of future operations. Advisory on documentation requirements and international best practices. Review of companies’ Transfer Pricing Manuals and their compliance with local regulations.
    • Advance pricing agreements: Assistance and negotiation of advance pricing agreements with the Tax Administration.
    • Conflict resolution: Legal defense and representation in litigation processes related to Transfer Pricing matters.

Latest News


Key Contacts

Mario Estuardo Archila



Diego Martín


El Salvador

Armando Manzanares



Carlos Taboada



Rafael Luna


Costa Rica