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March 22, 2023

Costa Rican Tax Authority creates National Large Taxpayers Dialogue Forum

  • The new National Large Taxpayers Dialogue Forum seeks to create a space for dialogue and the exchange of solutions for general tax issues of common interest.

  • Representatives from the tax authorities and national large taxpayers will participate in the Forum.

  • The representatives of the national large taxpayers will be chosen based on criteria included in the resolution.

On 22 March 2023, Costa Rica’s General Directorate of Taxation (known as the Tax Authority) published in the Official Gazette resolution No. MH-DGT-RES-005-2023, creating the National Large Taxpayers Dialogue Forum (Forum) (in Spanish, “Foro de Diálogo con Grandes Contribuyentes Nacionales”).

The purpose of the Forum is to promote openness and collaboration among companies classified as national large taxpayers and the National Large Taxpayers’ Directorate (in Spanish, “Dirección de Grandes Contribuyentes Nacionales”) by sharing knowledge, participating in discussion, and exchanging solutions to general tax issues of common interest.

The Forum will be compromised of: (i) an Executive Committee, staffed by representatives of the General Directorate of Taxation and the National Large Taxpayers’ Directorate; (ii) representatives of the Technical Regulatory Departments of the General Directorate of Taxation; and (iii) representatives of the national large taxpayers.

The national large taxpayer representatives will be the 14 largest national taxpayers from the Large National Taxpayers Census and distributed as follows:

  1. The five largest national taxpayers from the private sector

  1. A maximum of three national largest taxpayers from the commerce, industry, services and government sectors (not included in the five largest national taxpayers from the private sector), selected based on: (i) their billing volume; (ii) their income; or (iii) the interest that the Tax Authority has in their participation

When discussing certain topics, the Forum may include other national taxpayers or interest groups. These other participants must be formally called by the Forum and only for an established period.

The Forum may conduct its work through plenary sessions or through one or more working groups, depending on the interest of its representatives. The Forum must hold a plenary session at least once a year and call on the working groups when specific issues need to be discussed.

The Resolution entered into force after its publication in the Official Gazette.


For additional information with respect to this Alert, please contact the following:

Ernst & Young, S.A., San José, Costa Rica

Ernst & Young LLP (United States), Latin American Business Center, New York

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific


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