A resolution (published 18 August 2015) establishes the standards relating to transactions between related parties, and specifically for the purpose of determining the threshold for claiming deductions of amounts paid as royalties or paid for technical, administrative, consulting, and similar services. In general, the deductibility threshold is set at 20%. However, a higher percentage may be available if the methodology relating to transactions between related parties is approved by means of a consultation with the tax administration.
The deadline for filing a consultation for a valuation determination is the last business day of March of the tax year for which the application of a higher deductibility threshold is sought.
If the taxpayer request a consultation for previous assessment and the tax administration notifies the taxpayer of its determination after the due date for filing the income tax return for the corresponding tax year, the taxpayer may file an amended or substituting return that reflects the higher deductibility threshold.
For more information, contact a tax professional with KPMG’s Americas Center:
Devon Bodoh | (202) 533-5681 | email@example.com
Alfonso A-Pallete | (305) 913-2789 | firstname.lastname@example.org
Or contact a KPMG tax professional in Ecuador:
Gino Erazo | (593) 4 - 229-0697 | email@example.com
Gabriela Cervantes | (593) 4 - 229-0697 | firstname.lastname@example.org
Karina Rubio | (593) 4 - 244-4225 | email@example.com
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.