Ecuador: local rules

Ecuador's transfer pricing rules are in the Ley de Régimen Tributario Interno (LRTI), in the unnumbered articles after article 15 (arm's length principle, comparability, prior valuation consultation), after article 4 (related parties), after article 22 (duty to price at arm's length and to file annexes and reports) and in article 23 (tax authority power to adjust). The Reglamento para la Aplicación de la LRTI (RALRTI) adds the detail in arts. 4 and 84 to 91. Parties are related through management, administration, control or capital. The Reglamento gives 25% or more of the capital, or 50% or more of sales or purchases with one party (after the SRI notifies the taxpayer), as links to look at. Dealings with tax havens or lower tax jurisdictions also count, and the SRI may find a related party by presumption when prices are not arm's length. The OECD Transfer Pricing Guidelines in force on 1 January of the tax year are the technical reference (RALRTI art. 89). SRI Resolutions NAC-DGERCGC15-00000455 (content of the annex and report), NAC-DGERCGC16-00000531 (anti-abuse measures) and NAC-DGERCGC16-00000532 (technical rules and method order) complete the rules. The old exemption from the regime for taxpayers with tax paid above 3% of income was repealed on 20 December 2023 by the Ley Orgánica de Eficiencia Económica y Generación de Empleo (art. 9), so no exemption remains.

Two filings exist. The Anexo de Operaciones con Partes Relacionadas (annex, also called OPR or APR) is due from income tax payers whose related party operations in a tax year add up to more than USD 3,000,000. The Informe Integral de Precios de Transferencia (IIPT, a full local style report with workpapers) is due in addition when they add up to more than USD 10,000,000 (Resolution NAC-DGERCGC15-00000455 art. 2, as replaced by NAC-DGERCGC23-00000025). The IIPT limit was USD 15,000,000 until tax year 2022 and has been USD 10,000,000 from tax year 2023 (SRI bulletin NAC-COM-24-050). Some items are left out of the total, such as cash capital contributions, cash dividend payments, income taxed under arts. 27, 27.1 and 31 LRTI, dealings with public bodies, operations covered by an approved advance valuation, and most liabilities other than loans taken in the year. Local related party dealings are left out unless certain conditions apply (art. 3). The annex is sent online on the SRI technical form. The IIPT is a PDF-text file with a signed letter and all workpapers, built on the SRI technical sheet (ficha técnica). A new IIPT cannot be filed for a year the SRI is auditing. The SRI can also ask for support on any dealing of any size, with at least 2 months to answer. No separate master file or country-by-country report was found (see other).

RALRTI art. 85 lists five methods: comparable uncontrolled price, resale price, cost plus, profit split and transactional net margin. The SRI sets technical rules and a method order by resolution (NAC-DGERCGC16-00000532). That resolution is a scanned image and its order of methods was not read. When there are two or more comparables, the taxpayer must find the median and the arm's length range, which runs from the first to the third quartile (the interquartile range, art. 87). A value inside the range is accepted. A value outside it is replaced by the median. The SRI may use any information, its own or from third parties, as secret comparables (art. 90). Taxpayers can ask for a prior valuation ruling that binds for the current year, the year before and the next three years (LRTI and RALRTI art. 88). The SRI has to answer within 2 years. A circular of 25 March 2026 (NAC-DGECCGC26-00000001) says that the OECD Pillar One Amount B simplified approach for distributors has not been adopted in Ecuador.

Fines are set by taxpayer type in SRI Resolution NAC-DGERCGC15-00000455 arts. 12 to 14 (added by NAC-DGERCGC24-00000020), under a legal cap of USD 15,000 for each obligation (LRTI, RALRTI art. 84). Not filing the IIPT costs USD 15,000 for a large taxpayer, USD 7,500 for a special taxpayer and USD 3,750 for others. Not filing the annex costs USD 10,000, USD 5,000 and USD 2,500. Filing an incomplete, wrong or inconsistent annex or report (for example one that differs from the Form 101) costs up to USD 15,000, USD 7,500 or USD 3,750 if the SRI finds it first, and 75% of that if the taxpayer pays on its own before any notice. Late filing costs USD 1,000, USD 500 or USD 250 if the SRI assesses it, and USD 750, USD 375 or USD 187 if the taxpayer pays on its own.

Ecuador has not enacted the OECD GloBE rules as far as could be confirmed on 27 October 2026. No income inclusion rule, undertaxed profits rule, qualified domestic minimum top-up tax or GloBE information return was found in the LRTI, the RALRTI, the SRI international taxation page or the PwC Worldwide Tax Summaries (last reviewed 23 July 2026). So there is no Pillar Two filing deadline for Ecuador. The general corporate income tax rate is 25% (LRTI art. 37), which is above the 15% GloBE minimum rate.

The tax year is the calendar year (LRTI art. 7). The corporate income tax return is Formulario 101. Companies file and pay in April, on a day set by the ninth digit of the RUC (RALRTI art. 72): digit 1 on 10 April, then every second day up to 26 April for digit 9 and 28 April for digit 0. Special taxpayers file by 11 April, public bodies by 20 April, and taxpayers based in Galápagos by 28 April (Resolution NAC-DGERCGC23-00000034). The tool shows the earliest digit day, so check your own RUC digit. The annex and the IIPT are due no more than 2 months after the return date (RALRTI art. 84), which gives June, on the same digit days (10 to 28 June). The SRI moved them to September for tax year 2023 (Resolution NAC-DGERCGC24-00000020) and tax year 2024 (Resolution NAC-DGERCGC25-00000012), each time by a one-off transitional rule. No such move was found for tax year 2025. No country-by-country report, master file or CbC notification rule was found, so none is listed here.