
Transfer Pricing and the Problem of International Double Taxation in Central America
When transfer pricing adjustments are made in Central America, the regulations adopt the so-called “correlative adjustment”...

“Rafael Luna has strong technical knowledge and is well connected to the relevant authorities. His opinion holds particular weight in Costa Rica.”
Rafael is a Partner at Consortium Legal – Costa Rica. With more than 26 years of experience, he specializes in Tax Law and Transfer Pricing. He has extensive expertise in tax consulting, litigation, mergers and acquisitions, mainly for multinational as well as local companies. He currently leads the firm’s Tax and Transfer Pricing Practice, overseeing some of the country’s most significant tax litigation cases.
He is an Official Expert of the Judiciary in Transfer Pricing and a frequent columnist for financial magazines and newspapers. He has served as a Consultant for the Inter-American Development Bank (IDB) for the training of Tax Administration officials, Professor at the University for International Cooperation (UCI), Professor and Director of the Master’s Program in Tax Advisory and the Master’s in Tax Law at ULACIT, Professor of International Taxation at CICAP – University of Costa Rica, and as a panelist at both national and international forums.
150mts oeste de la entrada principal de Oficentro El Cedral, Escazú.
Edificio Banco General 6° piso San José


When transfer pricing adjustments are made in Central America, the regulations adopt the so-called “correlative adjustment”...

The Central American region has been characterized by a very dynamic economic, political and social development,...
Since April 18, 2022, the Virtual Tax Administration (ATV) system has been inoperative due to a...
By: Rafael Luna The Transfer Pricing Guidelines were issued for the first time in 1995 by...