The new resolution grants taxpayers more time to comply with their Transfer Pricing obligations.
The SRI (Servicio de Rentas Internas – Internal Revenue Service) of Ecuador, through Resolution No. NAC-DGERCGC25-00000012 has extended the deadline for filing the Related Party Transactions Annex 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, according to the deadline schedule for their monthly tax returns, which is a significant extension of the obligations initially set by the regulations.
Who Is Subject 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 related-party transactions (they must also file the Comprehensive Transfer Pricing Report).
This amendment addresses the need to allow for a considerable margin for compliance and technical adaptation, considering the constitutional principles of simplification, speed, and efficiency in administrative action.
Legal Grounds 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 filing tax documentation. Failure to comply or filing with errors may result in penalties of up to USD 15,000, as provided for in current regulations.
TPC Group Recommendation
At TPC Group, we recommend that taxpayers:
- Leverage this extension to strengthen the quality of the functional and economic analysis of their intercompany operations.
- Verify in advance compliance with thresholds determining the obligation to file one or both reports.
- Avoid contingencies by reviewing in advance the consistency between the income tax return and the annexes/reports filed.
Need Technical Support to Prepare Your Transfer Pricing Report?
At TPC Group, we have a specialized Transfer Pricing team in Ecuador and Latin America. We assist in complying with all regulatory requirements, minimizing risks, and optimizing your tax structure.
Please mail us at contacto@tpcgroup-int.com or visit www.tpcgroup-int.com
Avoid penalties and comply on time with the support of experts!