Impact of BEPS Actions on Costa Rican Transfer Pricing Regime

The author considers the current effects on the Costa Rican transfer pricing regime of the international adoption of the recommendations of the BEPS Actions related to transfer pricing, including Action 13 (regarding transfer documentation) and Actions 8, 9 and 10 (which deal with specific topics and have modified several chapters of the OECD Guidelines). First, the background of the BEPS Actions and the transfer pricing regime are described, followed by an assessment of the effects of each of the Actions.