Ecuador Gazettes Circular Clarifying Transfer Pricing Approach Related to OECD Pillar One Amount B Activities

The Ecuadorian Official Gazette March 25 published Circular No. NAC-DGECCGC26-00000001, clarifying the transfer pricing approach for taxpayers engaged in OECD Pillar One Amount B activities. The circular clarifies that: 1) Ecuador has not enacted as part of its tax regime, the simplified and streamlined approach for eligible operations conducted by taxpayers engaged in Pillar One Amount B marketing and distribution activities, as established under the OECD Transfer Pricing Guidelines; and 2) the transfer pricing analysis for these activities involving related parties must, therefore, be conducted according to the regime established under the Internal Tax Regime Law, its regulations, and Internal ...