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 requirements (Local file), including details of the structure, business strategy, main competitors, transactions, comparability analysis and transfer pricing methods used, copies of APAs and relevant tax rulings, etc. The draft resolution includes that the...