On 5 December 2014, Ecuador published Resolution NAC-DGERCGC14-00001048 in the Official Gazette. The Resolution introduced the procedures for a taxpayer to apply for an advance pricing consultation (ruling) for related party transactions. The right to request such a ruling has been provided for under law since 2010, but no formal procedures have been introduced until the recently published resolution.
Under the procedures introduced by the resolution, a taxpayer may first propose a draft con…