The new resolution grants taxpayers more time to comply with their transfer pricing obligations.
The Internal Revenue Service (SRI) of Ecuador, through Resolution No. NAC-DGERCGC25-00000012, has extended the deadline for filing the Annex on Related Party Transactions and the Comprehensive Transfer Pricing Report for the 2024 tax period.
What is the new deadline?
As established, taxpayers may file these documents until September 2025, in accordance with the schedule of deadlines for their monthly tax returns. This represents a significant extension of the obligations initially provided for in the regulations.
Who does this measure apply to?
The obligation to file these reports falls on income tax taxpayers who, during the fiscal year:
- Have carried out transactions with related parties for a cumulative amount exceeding USD 3 million (mandatory annex).
- Have exceeded USD 10 million in transactions with related parties (they must also file the Comprehensive Transfer Pricing Report).
This change responds to the need to allow greater margin for compliance and technical adaptation, considering the constitutional principles of simplification, speed, and efficiency in administrative actions.
Legal basis and technical support
The resolution is based on Article 84 of the Regulations for the Application of the Internal Tax Regime Law and on the powers granted to the SRI to define the deadlines and formats for the submission of tax documentation. Failure to comply or submit the documentation with errors may result in penalties of up to USD 15,000, as provided for in the current regulations.
Recommendation from TPC Group
At TPC Group, we recommend that taxpayers:
- Take advantage of this extension to strengthen the quality of the functional and economic analysis of their intercompany operations.
- Verify in advance compliance with thresholds that determine the obligation to file one or both reports.
- Avoid contingencies by checking in advance the consistency between the income tax return and the annexes/reports submitted.
Do you need technical support to prepare your Local File?
At TPC Group, we have a team specialized in transfer pricing in Ecuador and Latin America. We help you comply with all regulatory requirements, minimizing risks and optimizing your tax structure.
Write to us at contacto@tpcgroup-int.com or visit en.tpcgroup-int.com
Avoid penalties and comply on time with the support of experts!