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Ecuador: Transfer pricing methodology for banana exports; other transfer pricing reforms

Ecuador: Transfer pricing methodology, banana exports

Guidance provided by two resolutions addresses (1) the transfer pricing methodology with regard to banana exports and (2) the use of data from comparable independent third parties in certain instances.


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One resolution sets forth the transfer pricing methodology for banana exports involving related parties in other countries. Specifically, formulas are provided regarding the transfer pricing determination for banana exports involving related parties in the EU, Russia, and other countries.

A second resolution concerns the analysis of data from comparable independent third parties. Under this guidance, the latest financial information from comparables (data that is available before the due date for the taxpayer to submit the declaration of income tax for the subject year) can be used. Absent the availability of the most recent financial information from comparables, the taxpayer can use the information from the year immediately prior to the subject year closing on or after 31 August—provided that there have been no changes to the relevant conditions.

Read a July 2020 report (Spanish) [PDF 123 KB] prepared by the KPMG member firm in Ecuador

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Ecuador:

José Miguel Vega |

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