The General Tax Office and the Costa Rican Institute on Drugs issued a new Joint Resolution of General Scope for the Registry of Transparency and Ultimate Beneficiaries No. DGT-ICD-R-06-2020, which was published in La Gaceta No. 65 of March 30, 2020. Through this Resolution, the previous resolution is repealed, and important changes are issued in relation to the filing of the ordinary declaration of this registry, some of them are:

  • Modification of the filing date of the ordinary declaration: It is transferred from April to September of each year.
  • Definition of the form of filing of the ordinary declaration: The last declaration presented will be preloaded, to facilitate the update of the data that has changed or simply confirm that the declaration has no changes.
  • Allow more space to correct the ordinary declaration: When an error is identified in the ordinary declaration sent.
  • Clarification on the filing deadline for new companies: 20-business-day filing deadline following registration or assignment of ID and in the event that this occurs within the month of September, they may have 20 business days or the month of September, depending on the most favorable term for these.
  • Elimination of Apostille / authentication in the case of legal persons listed on an organized stock market: In the case of legal persons listed on a foreign stock market, the requirement of apostille or consular certification is eliminated in the supporting documentation.
  • More flexibility: increase of the type of the supporting documents that can be provided to prove impossibility of supplying information to persons domiciled abroad, and registration of participants with incomplete information is enabled.
  • Exception for companies incorporated in 2020: Legal entities that are assigned a certificate number in the National Registry, either by registration or by request, between January 1 and August 31, 2020, must not file the first declaration within the next 20 business days and instead, for this time only, they will present it in September 2020.
  • Deadline for changes to 2019 declarations: Legal entities that must file an extraordinary declaration or make corrections for the 2019 declaration period (September 2019 to March 2020) and before the annual declaration of September 2020, for this time only, will present said changes in the annual declaration that must be filed in the month of September 2020.
  • Presumption of the Ultimate Beneficiary: If it is not possible to identify it, the person who occupies the top management position of the legal entity that makes the declaration will be finally considered the ultimate beneficiary.

BLP has attorneys who are experts in Commercial and Tax Law who can provide advice to your company regarding this changes.