Practice
Transfer pricing and international tax
Compliance and defense of related-party transactions, and taxation of cross-border transactions.
Talk to a partnerWe prepare and review transfer pricing reports and annexes, and defend those positions before the SRI and in court, with our own expert witness. The technical and legal strategies are designed together from the tax authority’s first request.
Shortlisted · Transfer Pricing Firm of the Year, Ecuador · ITR Americas Tax Awards 2026
ITR World Tax 2026 · Other notable · Transfer pricing
Scope
- Comprehensive transfer pricing report and related-party annex
- Comparability analysis and pricing policies
- Defense and expert witness work in transfer pricing proceedings
- Double tax treaties and payments abroad
- Foreign financing and Currency Outflow Tax (ISD)
- Customs regimes and foreign trade
Representative experience
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
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
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
Partners’ 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
