Moratorium for the Shareholder Registry
Update: A new moratorium on the Registry of Transparency and Final Beneficiaries was published April 23rd establishing a new period grace on the requirement. Even though the rules on how the subsections of Law 9810 are going to work are not clear yet, per yesterday’s update, corporations have 6 additional months to comply with the period 2019.
A moratorium on sanctions has been established for a maximum non-extendable term of 3 months in the
case of those failing to file the 2019 Registry for Final Shareholder Beneficiary as set out in the Joint
Resolution of General Supplement for the Regulations on the Registry for Final Shareholder Beneficiary.
The Directorate General for Direct Taxation will impose the applicable sanctions on any non-complying
person(s) as follows:
a) No sanctions will be imposed within the first 2 months of this moratorium.
b) A fine will be applied equal to 50% of the corresponding penalty to be assessed if the filing should take
place during the third month of the moratorium.
c) Non-filing of the registry or filing on a date following the end of the third month of the moratorium will
render the sanction set in Article 84 bis of Law 4755 or Code of Tax Regulations and Procedures.
This moratorium does not exempt the obligated party from filing the 2019 Registry for Final Shareholder
Beneficiary, pursuant to the above Joint Resolution issued by the Costa Rican Drug Institute.