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13.4.3. APAs and Dispute Resolution Mechanisms


Advanced pricing agreements (APA) are available in Costa Rica. When applying for an APA, the taxpayer must submit a proposal for the transfer price of the transaction in question. If an agreement is reached with the tax authorities, the APA will be valid for 3 years.


If an adjustment is proposed by the tax authorities, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/assessments (See Sec. 14.7.).