Costa Rica has published Resolution DGT-R-018-2018 in the 12 April 2018 edition of the Official Gazette (found under various documents - documentos varios). The resolution updates the criteria for the classification of a taxpayer as a Large Taxpayer or Large Territorial Taxpayer, as well as certain related rules, including the mandatory use of electronic forms for tax purposes by taxpayers classified as large.

The resolution provides that a taxpayer will be classified as a Large Taxpayer if meeting any one of the following criteria:

• Average tax paid in the previous three fiscal periods is equal to or greater than CRC 450 million;
• Average gross income in the previous three fiscal periods is equal to or greater than CRC 40 billion;
• Average total assets declared in the previous three fiscal periods is equal to or greater than CRC 50 billion;
• The taxpayer is regulated by the Superintendencies of Financial Institutions, of Securities, of Pensions, of Insurance, or of Telecommunications, or the  taxpayer forms part of financial conglomerates and groups that are not supervised by the listed regulators but is of interest to the tax authority;
• The taxpayer is linked in their operations with a Large Taxpayer and represents a fiscal interest for the tax authority; or
• The taxpayer has been identified as a risky taxpayer based on significant deviations in tax behavior as compared to their sector or economic activity, including a relatively low tax contribution.

For classification as a Large Territorial (Regional) Taxpayer, the following criteria apply:

• Average tax paid in the previous three fiscal periods is equal to or greater than CRC 120 million;
• Average gross income in the previous three fiscal periods is equal to or greater than CRC 20 billion;
• Average total assets declared in the previous three fiscal periods is equal to or greater than CRC 25 billion;
• The taxpayer is linked in their operations with a Large Territorial Taxpayer and represents a fiscal interest for the tax authority; or
• The taxpayer has been identified as a risky taxpayer based on significant deviations in tax behavior as compared to their sector or economic activity, including a relatively low tax contribution.

When the tax authority has determined that a taxpayer should be classified as a Large Taxpayer or Large Territorial Taxpayer based on the above criteria, a resolution will be issued to notify the taxpayer and the classification will take effect from the first day of the month following the notification. Once the initial notification is made, the classification as a Large Taxpayer or Large Territorial Taxpayer will apply for at least two years, even if the criteria are no longer met.