Ecuador master file and local file requirements (2026)

What are Ecuador's latest transfer pricing rules?

Two changes in late 2023 widened the net, and both still catch groups out. In September 2023 the trigger for the comprehensive report was cut from USD 15,000,000 to USD 10,000,000^[1]. In December 2023 the exemption that freed taxpayers whose tax burden exceeded 3% of taxable income was repealed^[2]. A company that sat outside the regime on that test now sits inside it.

Any source still quoting a USD 15,000,000 trigger is quoting the rule as it stood before September 2023.

Does Ecuador require a master file and a local file?

No master file. The comprehensive report does the local file's job, and the group-level file you prepare for other jurisdictions has no home in Ecuador. Ecuador is not one of the 38 OECD member countries^[3] and does not appear on the Inclusive Framework membership list updated in December 2025^[4], so the master file standard never reached it through membership.

For a foreign parent the practical translation is short. The entity-level analysis you would write into a local file goes into Ecuador's comprehensive report instead, and the group file stays where it was prepared.

Who has to file transfer pricing documentation in Ecuador?

Any Ecuadorian taxpayer whose related-party transactions pass the thresholds, including the local subsidiary of a foreign-headquartered group. There is no carve-out for small entities inside a large group, and the 3% tax burden exemption that used to release some taxpayers was repealed at the end of 2023.

The ownership percentage that makes two parties related sits in the income tax law and its regulation. We could not confirm that figure against a primary text, so this page does not state one.

What are Ecuador's transfer pricing thresholds?

Two thresholds, both measured on related-party transactions accumulated across the whole fiscal year rather than per counterparty. The tax authority sets the current thresholds, deadlines and fines in one resolution^[5].

A lower trigger for dealings with tax havens and preferential regimes is widely reported. We could not confirm it against primary guidance, so it is left out rather than stated.

What goes in Ecuador's two transfer pricing filings?

The annex is data and the report is argument. The annex lists every related-party transaction by counterparty, type, amount and method. The report carries the functional analysis, an industry and company overview, a transaction-by-transaction analysis, and the method chosen for each transaction with the comparables behind it.

Both are filed. Neither is a file you keep and hand over when asked. Whether the tax authority prefers local or regional comparables, and how often a benchmarking study has to be refreshed, is not confirmed from a primary source, so this page states no rule for it.

Does Ecuador require country-by-country reporting?

No country-by-country obligation and no notification rule appear in Ecuadorian law. Ecuador sits outside the Inclusive Framework that runs the country-by-country exchange standard, so there is no membership route into it either.

For a parent used to filing country-by-country reports elsewhere this is the useful negative. Ecuador wants the annex and the report, and nothing above them.

When is Ecuador transfer pricing documentation due?

Within two months of the income tax return deadline, for both filings. That window comes from the regulation under the Internal Tax Regime Law^[6]. Recent years ran on one-off transition dates instead of the standing rule, so check which one applies to the year you are filing for.

A June 2025 resolution^[7] set the fiscal year 2024 extension. The income tax return month itself, and any transition for fiscal year 2025, are not confirmed, so read the tax authority's own filing calendar^[8] before you fix a 2026 date.

What language and currency does the documentation use?

US dollars. Ecuador has been dollarized since 2000, so every threshold and every figure is already in the currency it is filed in and there is no conversion to argue about. The statutory language rule is not confirmed; Spanish is the working assumption for anything filed with the tax authority.

What are the penalties for getting Ecuador transfer pricing wrong?

Fines are fixed cash amounts, graded by taxpayer class and charged per document. A large taxpayer pays the full amount, a special taxpayer half of it, any other taxpayer a quarter. Correcting a filing yourself always costs less than having the tax authority find the error.

What is a foreign parent exposed to in Ecuador?

Stacked fines, because each missing document is its own infraction. A large taxpayer that files neither the annex nor the report pays USD 10,000 plus USD 15,000. An incomplete filing is penalised separately from a missing one, so filing an annex badly does not close the exposure.

Voluntary correction is the cheaper path by a wide margin. For a large taxpayer, a wrong filing corrected on its own initiative costs USD 11,250. The same error found by the tax authority costs USD 15,000.

How we help with Ecuador transfer pricing

Ecuador gives a foreign parent two filings to track, each with its own threshold, its own deadline and its own fine, and the two fines add up. We build the comparables and the functional analysis, draft the annex and the comprehensive report, and file both inside the window. See how our transfer pricing software works.

Book a demo to find out which Ecuador filings your group already owes for the year just closed.