Founding Partner · Transfer Pricing
Geovanna Cerda Mosquera
Certified public accountant and transfer pricing specialist with more than 16 years of experience in financial audit, compliance and controversy. She heads TRIARIUS’s transfer pricing practice.
Transfer pricing · Transfer pricing controversy · Expert witness · International tax
- Phone
- +593 2 450 7532
Recognition
- ITR World Tax: Highly Regarded in tax controversy for six consecutive years (2021–2026)
- ITR: Women in Tax Leader (2026)
Career
- Financial audit and transfer pricing at Deloitte Ecuador
- Court-accredited expert witness (Consejo de la Judicatura) in transfer pricing disputes
- Experience in aviation, automotive, oil, mining, manufacturing, distribution, retail, palm oil, real estate, fisheries and services
- Founding partner of TRIARIUS (2024)
Representative matters
Under professional confidentiality, we do not identify our clients.
Floriculture · Transfer pricing
An SRI audit of nearly eighteen months into a flower exporter’s transfer pricing report
Closed with no transfer pricing adjustment
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
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
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
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
Fisheries · Compliance
Remediation of a transfer pricing report prepared by a foreign adviser, with penalty exposure
Report filed in line with Ecuadorian rules, with no penalty
Education
- Certified Public Accountant (CPA), Business Finance and Audit
- Master’s in Taxation
Teaching and memberships
- Teaches transfer pricing courses and workshops and speaks at national and international conferences
Publications and speaking
- Speaker at ASIPI Quito 2023: “Big Brother is watching: IP and International Taxation”
