Register of Transparency and Ultimate Beneficial Owners
03 March 2021
In order to follow up the process of the Registry of Transparency and Ultimate Beneficial Owners and to keep you informed of the provisions governing this obligation, we would like to inform you the following:
The Joint Resolution of General Scope for the Registry of Transparency Ultimate Beneficial Owners No. DGT-ICD-R-19-2020 dated August 6, 2020, issued by the General Tax Administration (Dirección General de Tributación) and the Costa Rican Narcotics Institute (Instituto Costarricense Sobre Drogas), modified the month when the information must be provided for the ordinary period; likewise, it established a number of transitory provisions regarding the declaration of the 2019-2020-2021 periods:
Due dates:
- Ordinary Filing: Once a year, during the month of APRIL.
-Extraordinary Filing: i) Within fifteen working days from the date on which any of the owners equals or exceeds 15% of the total shares. ii) Within twenty working days from the date on which a new company is incorporated or a corporate ID number (cédula jurídica) is granted. If this happens in April, it can be done within twenty days or the entire month, depending on the most favorable term.
Transitory provisions:
i) Legal entities that submitted the 2019 declaration in the RTBF system will not have to submit the 2020 declaration, since the RTBF system will automatically and for this only time, have that declaration as the one for that period. ii) Those companies that were assigned a cédula jurídica between 1 January 2020 and 31 March 2021 shall submit their declaration in April 2021 for this time only. Subsequent filings each April. ii) Legal entities that have to submit an extraordinary declaration or make corrections, either due to extraordinary changes or corrections after the 2019 declaration period (September 2019 to April 2020) and before the April 2021 annual declaration, for this only time, shall also submit such changes in the month of April 2021.
Given the above, you must proceed with the 2021 Ordinary filing.
If you have any doubts about the process or need any help to complete it, we are at your service.
