The return is filed in a day. It is defended over the four that follow.

We consolidate your tax and corporate obligations into a single calendar, and build the documentary support that will hold each transaction up when the authority asks.

Annual subscription · Module of the umbrella, or a standalone engagement

Almost no tax contingency is born of a reckless decision. It is born of a reasonable transaction that was documented badly, or not at all, and that years later nobody can explain because the team changed and so did the authority’s criteria. The work, then, is not filing. It is leaving every transaction in a condition to be defended: with its economic rationale in writing, its contractual support, and its corporate filings current. That is not done during the review — it is done while the transaction is happening.

The real exposure

The tax authority does not review the current year: it reviews backwards. Following the 2021 reform, its assessment power lapses four years from the filing of the original return, and six years where no return was filed. That means the file nobody is assembling today is the one that will have to support a transaction when the team that decided it is no longer there.

For related-party transactions the bar rose. In March 2026 the Servicio de Rentas Internas (Ecuador’s tax authority, SRI) issued circular NAC-DGECCGC26-00000001, expressly rejecting the simplified «Amount B» approach of the OECD’s Pillar One for lack of statutory authority: the analysis must be done through detailed comparability, on concrete functions, assets and risks, under the arm’s length principle of the Internal Tax Regime Act. Standardized international benchmark margins are no longer sufficient support.

On the corporate side the logic is the same: an unfiled set of minutes, a lapsed appointment or an unregistered capital increase are not pending formalities. They are the point at which a sale, a loan or a due diligence stops.

How we do it

Method and deliverables, with a written timeline for each step.

Step	What we do	What you get	Timeline
1 · Assessment	Review of returns, intragroup contracts, minutes and corporate filings	Exposure report with a status rating by area	10 business days
2 · Calendar	Tax and corporate obligations with owner and date	Tax and corporate calendar	10 business days
3 · File	Building the support per transaction: economic rationale, contracts, filings	Defensible file	30 to 60 business days
4 · Maintenance	Support at closings, review of new transactions, and handling of information requests	Semi-annual report for management	Ongoing

Concrete deliverables

A single calendar of tax and corporate obligations, with internal owner and date
An exposure report with a status rating by area, and a written label for each status
A supporting file for each material transaction, with its economic rationale and contractual backing
Intragroup contracts drafted or reviewed so they reflect the actual transaction
Corporate standing brought current: minutes, appointments, capital increases and filings
A protocol for responding to information requests, with deadlines and owners
A semi-annual report in business language for management and shareholders

How we charge for this service

Before you write to us

Frequently asked questions.

Does this replace my accountant or my external auditor?

No. The accountant records and files; the auditor opines. We build the legal support that neither of them produces and that is exactly what the authority asks for on review.

How far back can the SRI review me?

Following the 2021 reform, four years from the filing of the original return, and six if you did not file. That is why the file is assembled now.

My company is small — do transfer pricing rules still apply to me?

It depends on the volume and type of related-party transactions. The assessment determines it before any fees are committed.

I use international benchmark margins. Is that enough?

Since the March 2026 circular the SRI requires a detailed comparability analysis and has rejected the simplified Pillar One approach. Standardized margins are no longer sufficient.

What if I already have overdue corporate obligations?

The assessment identifies those first. Regularizing before a sale or a loan stalls always costs less.

Do you act for individuals and not only companies?

Yes, particularly for shareholders and business families, where the personal and corporate structures affect one another.

Do you work with foreign companies without a local operation?

Yes. It is one of the practice lines: international tax advice for foreign companies evaluating or maintaining operations in Ecuador.

If an assessment notice arrives, do you litigate?

Yes, through the strategic public law litigation service. This service exists precisely so that such litigation starts from a solid file.