• Moratorium on sanctions is established for 3 months.
  • The fines that were suspended amount to 2% of gross income of the previous fiscal year, with a minimum of 3 base salaries and a limit of 100 base salaries.

On January 29, 2020, the plenary of the Legislative Assembly approved a moratorium for the application of sanctions corresponding to the ordinary declaration corresponding to period 2019, related to the transparency register and final beneficiaries, provided by law 9416, law for improve the fight against tax fraud, of December 14, 2016.

According to the obligations of law 9416, all companies had to register before January 31, 2020 in a system created by the Central Bank for this purpose. If the legal entities fail to comply with this obligation, they were exposed to a fine of 2% of gross income of the previous year, with a minimum of 3 base salaries and a limit of 100 base salaries (upper limit of approximately US$ 80,000).

With the approved norm, the entities were granted with a moratorium of three months on the sanctions derived from the law. This moratorium cannot be extended.

The Tax Administration Office will impose on the obligor who fails to provide the information, within the period originally established, the corresponding sanction according to the following criteria:

a) During the first two months of validity of this moratorium, no sanction will be applied for failure to submit the declaration.

b) A proportional pecuniary fine of fifty percent (50%) of the sanction that would correspond in case of presenting the declaration during the third month of validity of this moratorium.

c) In case of not presenting the declaration or presenting it after the end of the third month of validity of this moratorium, the corresponding sanction will be applied.

This moratorium does not exempt the entity required to make the ordinary declaration for 2019 of filing the declaration in accordance with the provisions of the Resolution for the Transparency and Final Beneficiaries Registry issued by the Tax Administration Office and the Costa Rican Drugs Institute.

At BLP we have made hundreds of ultimate beneficiaries successfully. If you want BLP to assist you with this process, you can contact us at info@blplegal.com