1. Transfer Pricing Local File.
We Elaborate the local file or Transfer Pricing Report, as called in the Ecuadorian legislation, according with the Resolution No. NAC-DGERCGC15-00000455 and the Transfer Pricing Standarization Guidelines for Transfer Pricing, both regulated by IRS. This report contains the detail of the transfer pricing analysis in transactions between a company and its related or related parties for tax purposes and / or transactions with low or non-taxing countries or territories, considering the formalities required by the Tax Administration of Ecuador, the Internal Revenue Service (IRS).
2. Assistance in completing the Annex of Operations with Related and / or Foreign Parties (AOPR).
Elaboration of the Annex of Operations with Related Parties for companies with a formal obligation to upload the annex to the digital platform that the tax administration manages according to the periods established therein.
3. Advice on Transfer Pricing Planning.
Technical analysis that seeks to establish an optimal structure and valuation of operations between related or related parties and / or transactions carried out with countries or territories with low or zero taxation, in order to verify that the transactions analyzed comply with the principle of arm’s length or Full competition, and that the company maintains the corresponding supporting documentation.
4. Advice in Transfer Pricing determination process.
This service include an diagnostique of the arguments and conclusion that IRS arrived, the strategy, the document with technical arguments and the results, in order to give a complete advice in fiscalizations or requeriments os the Tax Authorities in Transfer Pricing in Ecuador.
5. Advice in the celebration of Advance Transfer Pricing Agreements (APA’s).
APAs are agreements between taxpayers and the tax administration, which seek to establish a valuation for transfer pricing, in advance, of transactions between related parties, and / or transactions with countries or Territories of low or zero taxation. Thus, a process is initiated in which an agreement must be reached on certain technical aspects, the most important being the following: the method allowed by the standard to be applied, comparison criteria and adjustments. Our service includes the elaboration and accompaniment until the effective celebration of the APA with the Tax Administration. The APA allowed the tax payer increase the deductible cost of royalties, technical, administratives and consulting services from related parties. The general limit is the 20% of the taxable income plus those expenses.