Tax Authority extends transfer pricing declaration deadline to October 15

The General Directorate of Taxation has moved, as a one-time exception, the filing of the Informative Return on Transfer Pricing for the 2025 tax period to October 15, 2026, from its original deadline of September 30, 2026. The measure is a response to a technical impossibility of the TRIBU-CR system recorded on that final day and was formalized in resolution MH-DGT-RES-0030-2026, published in La Gaceta No. 189 on Wednesday, October 7, 2026. The Tax Administration guaranteed that it will not initiate sanctioning proceedings against those obligated who comply within the extension.

The resolution was issued in San José at seventeen hours and thirty-five minutes on September 30, 2026, and signed by Miguel Ángel Solís Sánchez, General Director of Taxation and Competent Tax Authority, as stated in the official publication (reference IN202601130574). Article 1 orders the one-time move to October 15, 2026, for the filing of the return corresponding to the 2025 tax period, regulated in resolution MH-DGT-RES-0026-2025, from fifteen hours and five minutes on July 10, 2025, titled “Resolution regarding the filing of the Informative Return on Transfer Pricing.” Article 2 provides that the regulation is effective from its issuance and orders its publication once.

The General Directorate of Taxation based the decision on Article 99 of the Code of Tax Norms and Procedures (Law No. 4755 of May 3, 1971), which empowers it to issue general rules of mandatory compliance; Articles 18 of the Political Constitution and 18 of the Tax Code, regarding the duty to contribute and fulfill formal obligations; and Article 122 of the Tax Code, regarding self-assessment and payment within legal deadlines. It also invoked Article 103, subsection c), which identifies it as the department of the Ministry of Finance in charge of the administration and collection of taxes.

The origin: a TRIBU-CR system failure

Recital VI indicates that on September 30, 2026, the TRIBU-CR system experienced a technical impossibility to receive the informative transfer pricing returns for the 2025 tax period. TRIBU-CR is the sole platform for receiving sworn declarations for taxes administered by the General Directorate of Taxation, with general conditions regulated in resolution MH-DGT-RES-0011-2025.

The platform was developed under Law No. 9922, which approved Loan Agreement No. 9075-CR to finance the “Fiscal Management Improvement Project,” known as “Digital Finance for the Bicentennial,” between the Government of Costa Rica and the International Bank for Reconstruction and Development.

No sanctions and no public consultation

• No sanctioning proceedings for tax infractions shall be initiated against those obligated parties who comply with their formal obligation within the granted extension.
• The Public Consultation is waived pursuant to Article 174 of the Tax Code, as this is a one-time deadline extension and there is no impact on the substance of existing obligations and rights.
• The regulation does not create additional procedures, processes, or requirements for the administered party, according to Article 12 of Executive Decree No. 37045-MP-MEIC of February 22, 2012, “Regulations to the Law for the Protection of Citizens against Excessive Administrative Requirements and Procedures.”
• For this reason, prior control by the Regulatory Improvement Directorate of the Ministry of Economy, Industry and Commerce is not required.

Scope and validity of the extension

The resolution does not detail the universe of obligated subjects, but the extension applies to all tax obligors required to file the Informative Return on Transfer Pricing for the 2025 tax period. The new deadline is October 15, 2026, and it operates as a one-time measure, without modifying the substantive resolution that regulates the obligation.

The General Directorate of Taxation justified the urgency of regulating the matter due to the proximity of the deadline and the need to provide legal certainty to both the tax obligors and the Tax Administration itself.

The extension gives obligated companies fifteen additional days to comply with a filing whose non-compliance would have opened the way for sanctions, and the express guarantee of no sanction eliminates the risk for those who file within the new deadline. The measure also prevents a technological failure of the state platform from resulting in liability for taxpayers.

Source: La Gaceta No. 189, Wednesday, October 7, 2026, Miscellaneous Documents — Treasury, General Directorate of Taxation, p. 7 (official reference: MH-DGT-RES-0030-2026 / IN202601130574).