On 13 September 2016, Resolution N° DGT-R-44-2016 was published in Costa Rica's Official Gazette. The resolution sets out the requirements for the new transfer pricing declaration, which must be submitted annually by certain taxpayers. Affected Taxpayers The annual declaration requirements apply for: Large national or territorial taxpayers engaged in cross border related party transactions; and Taxpayers operating under the free trade zone regime established by Law 7210 of 1990. Status as a large taxpayer depends on certain conditions, which include meeting a threshold of CRC 40 billion (~USD 72.6 million) in gross income or average total assets in the previous...