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Costa Rica Publishes Draft Resolution on APA Procedure Guidelines

11 December 2019

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Proposed Changes

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Costa Rica

Costa Rica's Ministry of Finance has published a draft resolution for consultation on new guidelines on the procedures for entering into advance pricing agreements (APAs). The new guidelines take into account Costa Rican law, including the latest transfer pricing documentation requirements as set out in Resolution DGT-R-049-2019, as well as Costa Rica's transparency and spontaneous exchange of information commitments. The draft guidelines cover: The definition and competent authority for APAs; The information and documentation requirements when applying for an APA, which includes local file documentation as per Resolution DGT-R-049-2019; Additional information requirements for exchange purposes, which includes details on direct...