Ecuador: SRI gazettes resolution amending transfer pricing rules

25 September, 2023

On 13 September 2023, Ecuador’s Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. The resolution includes following measures:

Taxpayers who have conducted transactions with related parties totaling more than US$3 million in a single fiscal year must submit a report on these transactions.
Taxpayers who have conducted related-party transactions totaling more than US$10 million must also submit a comprehensive transfer pricing report.
Reservation of information means that the government has the right to disclose tax information under certain circumstances, even if the taxpayer believes that the information is confidential.
The SRI has moved to an electronic filing system for comprehensive transfer pricing studies. Previously, taxpayers had to submit the studies on a physical disc.

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