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.
