World TP Reviews

Transfer pricing

Tax and legal services in Ecuador have been provided through a Deloitte Legal member Firm, named RP&C Abogados, since 2001.The firm is member of Deloitte Touche Tohmatsu global network of professionals. Its national and international clients are active in the consumer products, energy, life sciences, technology and financial services sectors.   

The firm assists and prepares standardized economic analysis and reports for many multinational corporation’s regional subsidiaries. As LATAM coordinator, it the responsibility of facilitating all services to meet countries´ specific deadlines in the area. The group has been able to standardize transfer pricing reports for all their clients’ subsidiaries across the region.


The tax department of ECIJA GPA was formed in 2003 with the intention of providing services to clients facing pressure from Ecuadorian tax authorities. The firm assists clients in the areas of tax adjustments, negotiations on contracts with the Ecuadorian State, tax planning transactions, and merger and acquisitions.

Over the research period, the group supported the Lamor Corporation in two acquisitions from two shareholders. The matter engaged with regulations in Ecuador, Colombia and Peru.

Pérez Bustamante & Ponce

The tax department at Perez Bustamante & Ponce is comprised of three partners and nine associates, including accountants and engineers. Juan Gabriel Reyes and Maria Rosa Guerra lead the team. The group advises domestic and international companies on tax planning, tax structuring, cross-border M&A transactions, and project financing.

The transfer pricing group’s support enhances the firm’s corporate advisory services. Recently, it assisted Sony with a transfer pricing audit. As a result, the firm continues to represent the company in a judicial complaint filed against the Ecuadorian Internal Revenue Service. The matter relates to transactions between Sony and a local assembler, which the authorities considered related-party operations subject to the transfer pricing regime.


The firm of Robalino has a full-service tax practice. The group provides services related to, international tax, transfer pricing, customs, tax policy, litigation and cross-border transactions. It serves as an advisor for investors coming to Ecuador and to domestic businesses looking to do business abroad. The department is comprised of twenty tax professionals including, lawyers, and accountants.

The subdivision of transfer pricing provides services which are closely connected to the firm’s controversy work. It has advised Eurofish in a material tax audit on a transfer pricing issue for the 2014 Fiscal Year. The matter is the first transfer pricing litigation case in Manabí Tax Court Jurisdiction, making it a precedent setting case for the municipality.  

TP Consulting

TP Consulting Ecuador is an international consulting firm specialized in Transfer Pricing. The consulting practice serves clients in a diverse range of industries including food manufacturing, financial services, and pharmaceuticals.  

Over the recent research period, the team negotiated a total of eight Advance Pricing Agreements with the Tax Authorities. The group is a part of more ongoing matters in this area.

TPC Group

TPC Group is an International Transfer Pricing and Consulting Firm, made up of a network of strategic partners in Latin America, the USA and Spain. The group specializes in transfer pricing consulting; however, they also provide tax planning services to multinational groups.

Over the research period, the Ecuadorian office provided services to multiple large corporate entities which aimed to avoid future tax contingencies.