On June 7, 2025, the Internal Revenue Service (IRS), through Resolution No. NAC-DGERCGC25-00000012, decided to extend the deadline for the submission of the Annex of Transactions with Related Parties and the Comprehensive Transfer Pricing Report corresponding to the 2024 fiscal year until September 2025.
It is important to note that the due dates will align with those established for taxpayers’ monthly tax filings.
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This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.
On May 29, 2024, the Resolution No. NAC-DGERCGC24-00000020 issued by the INTERNAL REVENUE SERVICE was published in the Official Register. This Resolution reformed the contents of the Annex on Transactions with Related Parties and the Transfer Pricing Report whose most relevant content is summarized below:
The following classification of taxpayers was included for the establishment of the amounts of pecuniary sanctions regarding the report of the Annex on Transactions with Related Parties and the Transfer Pricing Report:
Taxpayers who do not submit the Transfer Pricing Report or the Annex on Transactions with Related Parties shall be fined based on the following table:
Type of Taxpayer | Failure to submit the Transfer Pricing Report | Failure to submit the Annex on Transactions with Related Parties |
---|---|---|
Large Taxpayers and Large Estates | USD 15.000 | USD 10.000 |
Special taxpayers | USD 7.500 | USD 5.000 |
Other taxpayers subject to the transfer pricing regime | USD 3.750 | USD 2.500 |
Taxpayers who submit incomplete, inaccurate or erroneous information shall be fined based on the following table:
Type of Taxpayer | Fine paid on a voluntary basis | Fine for facts detected by the Tax Administration |
---|---|---|
Large Taxpayers and Large Estates | USD 11.250 | USD 15.000 |
Special taxpayers | USD 5.625 | USD 7.500 |
Other taxpayers subject to the transfer pricing regime | USD 2.812 | USD 3.750 |
The Transfer Pricing Report or the Annex on Transactions with Related Parties shall be deemed to contain incomplete, inaccurate or erroneous information when the following are incurred:
When the taxpayer settles and pays the fine without prior notification by the Tax Administration, it shall be considered a voluntary liquidation.
If the Tax Administration notifies the taxpayer of the breach of its duties, a fine shall be issued based on the above categories.
Taxpayers who submit information after the deadline shall be fined based on the following table:
Type of Taxpayer | Fine paid on a voluntary basis | Liquidated by the Tax Administration in punitive proceedings |
---|---|---|
Large Taxpayers and Large Estates | USD 750 | USD 1.000 |
Special taxpayers | USD 375 | USD 500 |
Other taxpayers subject to the transfer pricing regime | USD 187 | USD 250 |
For more information, do not hesitate to contact our Tax Practice Partner, Iván García (igarcia@tzvs.ec).
© TobarZVS
This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.
By ZVS Tobar in TAX CONSULTANCY
On June 4th, 2024, the INTERNAL REVENUE SERVICE issued the BULLETIN No. NAC-COM-24-029, which enabled the new version of the annex for the report of the Tax Compliance Report (ICT, in Spanish), for the 2023 tax year. The changes are as follows:
For the registration of the Tax Compliance Report it is included in Annex 2 the columns regarding the specific annual movements of the taxpayer:
A 2. | Opening Balance | Movement of the year (DEBIT) | Movement of the year (CREDIT) | Final Balance |
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Annex 9 also includes the following sections for the registration of the taxpayer:
A 9. | Calculation of the maximum deductible value of resources and/or donations for undergraduate and postgraduate studies related to Education Sciences, delivered to Higher Education Institutions |
---|---|
Calculation of the maximum deductible value of donations, investments and/or sponsorships to environmental programs | |
Cálculo del valor máximo de deducibilidad de gastos operaciones de regalías, servicios técnicos, administrativos y de consultoría con parte relacionadas Calculation of the maximum deductible value for royalty, technical, administrative and consultancy operations with related parties |
Companies that have the obligation to have External Audit must submit the Report and its annexes until July 2024 through the web portal www.sri.gob.ec, according to its ninth digit of their tax registration identification.
Ninth digit | Maximum due date |
---|---|
1 | 10 de julio |
2 | 12 de julio |
3 | 14 de julio |
4 | 16 de julio |
5 | 18 de julio |
6 | 20 de julio |
7 | 22 de julio |
8 | 24 de julio |
9 | 26 de julio |
0 | 28 de julio |
For more information, do not hesitate to contact our Tax Practice Partner, Iván García (igarcia@tzvs.ec).
© TobarZVS
This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.
By ZVS Tobar in TAX CONSULTANCY
Non-profit private institutions will be exempt from paying income tax, as long as they use their assets or income for specific objectives and meet up the requirements established by law.
In addition, Tax regulations establish that at least 5% of the total income must come from contributions or donations.
On September 11, 2024, the Internal Revenue Service clarified, through Circular No. NAC-DGECCGC24-00000006, what will be considered as donations and contributions for private non-profit institutions to access the Income Tax exemption:
For more information, do not hesitate to contact our Tax Practice Partner, Iván García (igarcia@tzvs.ec).
© TobarZVS
This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.
By ZVS Tobar in TAX CONSULTANCY
On February 20, 2025, the Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC25-00000004, establishing the conditions for submitting the “Mining Annex.” Below are the most relevant aspects of its content:
Natural or legal persons who:
Holders of artisanal mining permits are exempt.
Obligated entities must submit the following information, as applicable:
The required information must be submitted through the SRI website on a semiannual basis. Submission deadlines will be determined according to the ninth digit of the Unique Taxpayer Registry (RUC), in September of the current year and March of the following year.
Failure to submit the annex or providing incomplete information constitutes an administrative violation, which may result in a fine of up to USD 1,000.
© TobarZVS
This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.
By ZVS Tobar in NATURAL RESOURCES, ENERGY AND INFRASTRUCTURE