New Transfer Pricing Rules in Ecuador

June 6, 2024


The Internal Revenue Service (SRI) has issued Resolution No. NAC-DGERCGC24-00000020, which establishes new reforms and guidelines for compliance with the Transfer Pricing regime in Ecuador. This resolution seeks to ensure transparency, fairness and efficiency in transactions between related parties.  

Legal Context

The Transfer Pricing regime in Ecuador is based on several articles of the Constitution of the Republic and the Tax Code. Specifically, Article 83 establishes the duties of the inhabitants to abide by the law and pay taxes; Article 300 defines the principles of the tax regime; and Article 6 of the Tax Code states that taxes also serve as instruments of economic policy.  

Taxpayers’ Obligations

According to the new resolution, taxpayers that carry out transactions with related parties must determine their income and costs considering prices and values of considerations similar to those of independent parties. In addition, they are required to submit specific schedules and reports to the Tax Administration on the established dates.  

Penalties for Non-Compliance

Failure to file or incorrect filing of Transfer Pricing reports will be sanctioned with fines that can reach up to US$15,000. Fines vary according to the type of taxpayer, being classified into large taxpayers, special taxpayers and other taxpayers subject to the regime.  

Filing Deadlines

For the 2023 tax period, taxpayers have until September 2024 to file the Schedule of Related Party Transactions and the Comprehensive Transfer Pricing Report. From the effective date of this resolution, the reports must be prepared according to the new technical sheets published by the IRS.  


The new guidelines established by Resolution No. NAC-DGERCGC24-00000020 seek to improve the transparency and efficiency of the Transfer Pricing regime in Ecuador. It is essential that taxpayers understand and comply with these obligations to avoid penalties and contribute to the economic development of the country.  

For more details, please consult the complete document on the Internal Revenue Service website (