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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 | jmvega@kpmg.com

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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