Ecuador’s Internal Revenue Service (SRI) issued a circular in March explicitly clarifying that the country has not incorporated the simplified Transfer Pricing (TP) approach proposed by the Organization for Economic Co-operation and Development (OECD), known as “Pillar One – Amount B”. This mechanism, designed to streamline the application of the arm’s length principle to basic marketing and distribution activities, was published by the OECD in February 2024 as a voluntary adoption option for jurisdictions.

Following the update of the thresholds applicable to the Information Regime for International Transactions and Transfer Pricing (TP), Form F.2668 has gained renewed relevance for taxpayers subject to the regime. In particular, the questionnaire included in Form F.2668 (the annual – return filed by taxpayers subject to the regime) has been expanded and reoriented towards a fiscal risk management approach, which means that, in practice, it may operate as a risk profiling tool for ARCA.

The landscape has changed, and that is already becoming apparent in practice. With the update to the sanctions regime applicable as of 2026, penalties for formal non-compliance in the area of International Operations have taken on significantly greater weight. And this doesn’t only affect large Multinational Groups: it can also impact importing or exporting companies, even when they operate with independent parties.

The General Directorate of Taxation has officially published Resolution MH-DGT-RES-0026-2025, which sets forth the general provisions for submitting the Transfer Pricing Informative Return (TP IR). This regulation aims to enhance tax control over related-party transactions, ensuring they are valued according to the Arm’s Length Principle.