According to the latest resolution issued by the Costa Rican Tax Authorities (published in the official newspaper “La Gaceta” N°65 on March 30^th, 2020) the date for the filing of the new annual declaration corresponding to the registration of all entities with a domicile in Costa Rica (including all Costa Rican companies) for the shareholders’ registry of the Costa Rican Central Bank (BCCR) , has been changed to the month of September 2020 (instead of April 2020 as it was originally established).   This applies to all companies and entities domiciled in Costa Rica, even if they already filed the mandatory initial declaration of shareholders for 2019, as the law establishes the obligation to update such declaration each year.

Furthermore, despite the initial rule, establishing short deadlines to file, because of this new legal change, all companies incorporated this year, as well as all existing companies that have made changes in their chain of share ownership, or in their by-laws (if such change is part of the corporate information that needs to be declared before this registry) will need to file in September 2020, being this their first report (in the case of companies incorporated in 2020) or to update their previous declaration of shareholders (for companies that reported in 2019 and subsequently transferred their shares).  Same timeline applies for entities wanting to correct errors on their 2019 shareholders registration, as the authorities clarified it will only be possible now in September of this year.

Finally, the above indicated resolution establishes new requirements for the declaration to be filed in September 2020 (information or documentation to be provided) in cases in which it is not possible to provide data related with the shareholders of the company or of its chain of share ownership. Furthermore, for any company part of the chain of share ownership being a publicly company traded on a foreign stock market, it is required also to file supporting documentation demonstrating such condition, and additional information related to the specific foreign stock market (such as the number of shares on stock, type of currency, date of registration, etc.).