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In Costa Rica, the transfer pricing methods are used to determine whether related-party transactions are adjusted to the arm’s length principle and aligned to the standards of the Organization for Economic Co-operation and Development (OECD). These methods are mainly regulated under the Regulations to the Income Tax Law, specifically in Articles 74 to 83.
Transfer Pricing Methods in Costa Rica, recognized in local regulations:
Comparable Uncontrolled Price (CUP) method
Resale Price (RP) method
Cost Plus (CP) method
Profit Split (PS) method
Transactional Net Margin (TNM) method
Residual Profit Split (RPS) method
Justified Alternative method