The Internal Revenue Service, through Circular No. NAC-DGECCGC26-00000001 dated March 25, 2026, issued a criterion for taxpayers applying Transfer Pricing methodologies regarding the "Pillar One – Amount B" guidelines, concerning special considerations related to baseline distribution activities. Among other aspects, the circular states:

Background

Ecuador considers the Transfer Pricing Guidelines of the Organization for Economic Cooperation and Development (OECD) as a technical reference in transfer pricing matters. On February 19, 2024, the OECD published the document “Pillar One – Amount B” which implements a simplified approach to baseline marketing and distribution activities, incorporating it as an annex to Chapter IV: “Administrative procedures for avoiding and resolving transfer pricing disputes” of the Transfer Pricing Guidelines of said Entity. The same document indicates that countries may choose to apply this simplified and optimized approach. Tax Administration

Pronouncement

Since no regulatory act has been issued providing for the application of Pillar One – Amount B, it has not been adopted nor is it applicable within the transfer pricing regime of Ecuador.

This is a summary of the cited Circular, contains information that we have classified as relevant and does not necessarily reflect the opinion of Robalino®; therefore, it cannot be considered as advice provided.

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