Bolívar Figueroa Martínez

Recognition

• The Legal 500, Tax, Ecuador: Next Generation Lawyer (2018–2019) and Rising Star (2020–2022)
• ITR World Tax: Highly Regarded in tax controversy (2023–2025)
• Who's Who Legal: Corporate Tax (2020)

Career

• Ecuador’s Internal Revenue Service (SRI), 2011–2014: legal and tax policy departments; took part in negotiating double tax treaties
• Adviser to the Government of Ecuador (2021–2022): member of CEPAI, the Tax Policy Committee, the National Civil Aviation Council and the port authorities
• Before TRIARIUS, advised on M&A in consumer goods, aquaculture and food, and on the tax defense of energy and engineering groups
• Founding partner of TRIARIUS (2024)

Representative matters

Under professional confidentiality, we do not identify our clients.

• Consumer goods · Tax controversy

  Full defense in an income tax audit reviewing transactions of more than USD 60 million

  Proposed assessments of more than USD 10 million neutralized during the audit

• Fishing industry · Multi-year controversy

  Defense against the reclassification of accounting accounts over three fiscal years, with a strategy for each year

  Settlement route under way for one of the years

• Agricultural exports · Ecuador and Chile

  Export pricing to a related party in Chile, coordinated with the Chilean tax authority’s review, and defense of reporting differences of about USD 2 million per year

  Defense ongoing for two fiscal years

• Transport · Compliance

  Challenge to a related-party transactions filing obligation the SRI sought to impose

  The SRI closed the case without imposing the obligation or any penalty

• Oil · International structuring

  Tax and transfer pricing structure for intercompany services, applying a double tax treaty

  The correct characterization of the transaction was upheld before the SRI

Prior experience

• Fisheries · Transfer pricing

  A USD 8 million transfer pricing adjustment against a fishing company

  Reduced to USD 3 million at the administrative stage; judgment with no adjustment, now on cassation

Education

• Leiden University
• Yale University
• Master’s in Tax Law, Universidad Andina Simón Bolívar; thesis on preventing the abuse of double tax treaties
• Law degree, Universidad de Las Américas (UDLA)

Teaching and memberships

• Lecturer at Universidad de Las Américas (UDLA) and Universidad Andina Simón Bolívar
• Member of the International Fiscal Association (IFA), Ecuador branch, and of the Ecuadorian Institute of Tax Law (IEDT)

Publications and speaking

• National reporter for Ecuador, Topic 1: international double taxation in VAT. 16th IFA Latin American Regional Meeting, Guatemala, 2026
• “Conceptos fundamentales del impuesto sobre la renta y la potestad tributaria de los Estados”, in Ensayos en homenaje al profesor José Vicente Troya Jaramillo, vol. II, UASB and IEDT, 2021
• Speaker at IFA regional meetings in Santo Domingo, Buenos Aires, Panama and San José, and at the ILADT Conference, Montevideo, 2018

Services

• Tax
• Corporate
• Commercial and contracts
• Administrative and regulatory
• Constitutional
• Employment
• Litigation
• Transfer pricing