On 12 December 2016, the Costa Rica Directorate General of Taxation published a draft resolution for public consultation on the introduction of transfer pricing documentation requirements based on Action 13 of the OECD BEPS Project. The draft resolution includes:
- Group information requirements (Master file), including details of the organizational structure, supply chain for top five products/services, functional analysis, intangibles and R&D, etc., and
- Local business information requir…