Protocol Amending the Tax Information Exchange Agreement (TIEA) Between Costa Rica and the United States

Article 2: Subject Matter

The Protocol requires each party to obtain and exchange information about Reportable Accounts, which are accounts held by U.S. or Costa Rican residents in financial institutions in the other country.

Information to be Exchanged

Account Holder Information: Name, address, and TIN (Taxpayer Identification Number) of account holders.
Account Details: Account number or functional equivalent, name and identifying number of the Reporting Financial Institution, account balance or value, interest, dividends, and other income generated by assets held in the account.

Article 3: Time and Manner of Exchange

The Protocol outlines the requirements for exchanging information regarding Reportable Accounts.

2014 Requirements

Only account holder information and account balance or value are required to be exchanged.
Information must identify the currency in which each relevant amount is denominated.

2015 Requirements

All information, except gross proceeds from sales or redemptions, must be exchanged.
Currency identification remains a requirement.

2016 and Subsequent Years

All information must be exchanged, including gross proceeds from sales or redemptions.
Currency identification is still required.

Article 3 (continued)

There are specific requirements for Reportable Accounts maintained as of June 30, 2014:

Taxpayer identifying numbers are not required if they are not in the records of the Reporting Financial Institution.
In such cases, the date of birth of the relevant person must be included instead.

Article 3 (continued)

The information described in Article 2 must be exchanged within nine months after the end of the calendar year to which the information relates.

Article 6: Arrangement for Automatic Exchange

The Competent Authorities of Costa Rica and the United States shall enter into an arrangement under the mutual agreement procedure provided for in Article 7 of the TIEA. This arrangement will:

Establish procedures for the automatic exchange obligations described in Article 2.
Prescribe rules and procedures as may be necessary to implement Article 5.
Establish procedures for the exchange of information reported under subparagraph 1(b) of Article 4.