Transfer Pricing: The tax risk many companies still underestimate
The Transfer Pricing Declaration is the technical document through which companies demonstrate that the prices set in transactions with related parties—such as group companies, partners, or linked entities—adhere to the Arm’s Length Principle. This means conditions must be comparable to those applied between independent third parties. ?
In March 2026, companies must file the Detailed Transfer Pricing Declaration (Form D-273) for the 2024 fiscal period.
Businesses conducting operations with related parties must maintain proper technical support, including a comparability analysis and the corresponding documentation.
The Risk: Non-compliance with this obligation can lead to fines of up to 2% of gross income, in addition to potential tax audits.
At Venegas Nexia, we support our clients in:
- » Evaluating compliance with the Arm’s Length Principle.
- » Preparing technical documentation (Local File / Master File).
- » Preventive identification of tax risks in related-party transactions.
@ To review your related-party operations, please write to us at [email protected] or contact us via direct message.
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