rate for the whole process to
register a company is about $250,
but there are opportunists in the
legal profession charging up to
$1,000. / A.M.
Costa Rica wire services photo.
Monday, November 4, 2019-
How to fill
out transparency forms
By Garland M. Baker
Exclusive to A.M. Costa Rica
Almost everyone with a company in Costa
Rica is a bit frustrated and worried about
filing their Registro de Transparencia y
Beneficiarios Finales (register of
transparency and final beneficiaries)
report to comply with Law 9416.
For those late to the ballgame, all the
ruckus is about the Costa Rican law
approved Dec. 14, 2016, but effective this
year. Those readers can refer to the
articles “Time to fess up or
pay up!,” published in Aug. 5,
and “How to register for
Law 9416,” published Sept. 2
for more information to get up to speed.
To sum up the news, Law 9416 was enacted
to quash privacy for legal entities formed
to protect secret investors. The Costa
Rican government asserts it will only use
the information it harvests to find tax
cheats, drug dealers and terrorists.
The report is due Jan. 31. Hacienda
(the tax department) will start dishing
out fines next February for non-filers.
That’s right, people have until the final
due date to file. Many are confused about
this fact because soft dates were
published based on the last digit of a
company’s identification number as its
filing deadline. The soft dates were a
guideline so everyone would not file
simultaneously by waiting until the last
Filers are experiencing many problems
hampering their abilities to comply with
the rules. Here are a few of them:
• A digital signature is required to file
the report. Appointments to obtain one are
hard to get.
• Many people do not have the
documentation for their company, or it is
• There are no instructions in English for
expats to understand what they need to do.
• Some legal professionals are charging
outrageous prices to file the reports.
Notary Ulises Obregón, reached by phone at
his office in San José, said, “. . . the
going rate for the whole process to
register a company is about $250, but
there are opportunists in the legal
profession charging up to $1,000.”
Those who do not want to pay capricious
fees and want to file the report
themselves need to obtain a digital
signature and then register with the
Central Directo system. Once they do those
things, they are ready to file the report.
Below is an overview of how to fill out
transparency forms for Law 9416. The
process is easy with the prerequisites
ready and a bit of patience. Here is a
list of the basics requirements:
•A good working knowledge of the Spanish
language or working with someone who does.
• A digital signature issued by the Banco
Central de Costa Rica.
• A recent literal certification of the
company to register issued by the Registro
• A reliable email. The system will send a
code to it to check if it is working.
• The phone numbers and addresses of each
owner of the company.
Once everything is together, it is time to
log into the Central Directo
system at the Banco Central to
register. Here are the steps:
• Put the digital signature card in its
card reader connected to a computer.
• Login to Central Directo.
• Click on the link in the upper left-hand
corner of the website named, “Ingrese.”
• A welcome message should appear.
• Select the second option, “En una
entidad suscrita donde está registrado(a)
como usuario,” in the middle of the page.
• The company or companies registered with
the system linked to the person’s digital
signature should appear as a list. Select
the one to register.
• Select the second option, “Registro de
Transparencia y Beneficiarios Finales.”
• For the first time user, a notification
email must be logged. There are three menu
options on the top of the screen, select
the first item in the list, “Correo para
notificaciones,” under the “Registro de
Transparencia” option. Input a working
email address. It will be verified by
sending a code to it for input into the
system before continuing.
• Once the email is verified, under the
same menu item, “Registro de
Transparencia,” select the first item in
the list, “Declaraciones.”
• On the screen, it is hard to see, but
there is a little plus sign right of the
two circular arrows on the left-hand side,
click it to add a report.
Now it's time to fill out the report. Here
are the steps:
Step 1: Periodo de la declaración
(Declaration period): The answer is 2019.
Step 2: Datos identificativos de la
persona jurídica (Identification data for
the entity): Using the literal
certification obtained from the Registro
Nacional, fill in the information. Contact
information for the filer will also be
requested and the email address verified.
Step 3: Capital social de la persona
jurídica (Capital stock of the entity):
Again, using the information from a
literal certification, fill in numbers.
Step 4: Detalle de los participantes
(datos identificativos y participaciones)
(Detail the participants by identification
and participation): For simple inactive
companies this section is simple. It is
more complex for active entities with
various stockholders. Simply input each
stockholder's ownership as a whole number
of the total number input in Step 3.
Step 5: Detalle de los beneficiarios
finales por otro tipo de control (Detail
of the final beneficiaries by other means
of control): This section is tricky. It is
for companies owned by other entities and
the like. If all the owners of a company
listed in Step 4 are real people, then
this section is not necessary, however, if
they are not or minors, this section must
be completed. This is where professional
assistance might be required.
The country intends to cross-reference the
data it captures with this new system with
other institutions to — again, as they
state — catch tax cheaters, drug people,
and terrorists. However, almost everyone
is noticing the government has with its
legislation over the last several years
completely stripped individuals of all
their privacy. They are even talking about
using the biometric data they collect when
they issue identification cards and
drivers licenses for facial recognition
The circumspect wonder if the government
is really trying to catch the bad guys or
their true intention is to have their
thumb on everyone.
Editor's note: Garland M. Baker is a
47-year resident and naturalized citizen
of Costa Rica. His team solves problems
for expats. Reach him at email@example.com.
Baker has undertaken the research leading
to his articles with A.M. Costa Rica. Find
the collection at crexpertise.info.
A free reprint is available at the end of
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