Tax in Ecuador

Bustamante Fabara

Bustamante Fabara stands out for the breadth of its tax service offering, which covers tax planning and contentious matters before administrative bodies and judicial courts. On the advisory front, the group is adept in advising domestic and international clients – including private and publicly traded companies, and high-net-worth individuals – on tax structuring mandates, direct and indirect taxation issues, and transfer pricing. Practice head Diego Pino, who was promoted to partner in 2024, has extensive knowledge of tax planning and tax optimisation matters, as well as tax disputes. Juan Carlos Bustamante is noted for his strong track record in cross-border transactions. Sofía Gordillo brings together considerable expertise in both tax and corporate law, while director María Fernanda Saá focuses on domestic and international taxation mandates.

Responsables de la pratique:

Diego Pino


Les références

‘Excellent support and communication.’

‘They focus first on fully understanding the business model and the reality of each company, to then be able to propose well-grounded tax solutions. The experience they have in various industries has allowed them to support us with innovative tax strategies.’

‘The team has a very good balance between youth and experience. This allows us to have confidence that they are technically prepared and up to date with the standards. On the other hand, the youth and innovative ideas component of the team is also very important for the constant changes that companies have.’

Principaux clients

Abbott Laboratorios Del Ecuador


Tiendas Industriales Asociadas Tia


Biela y Bebidas del Ecuador BIELESA (Heineken)


Grupo Ortiz


B. Braun Medical


Aglomerados Cotopaxi


Icesa


Lactalis Del Ecuador


Pepsico Alimentos Del Ecuador


Pfizer Cia


Oriflame Del Ecuador


Pharmabrand


Sociedad Hotelera Cotopaxi


Tessa Rosses


Mitsui


Maresa


South Ecuameridian


Basf


Jsv belzarubezhstroy


Olympic juice


Construmercado


Grupo Cid


Bimbo


Fadesa


Grupo Maderero Empresarial Gem Corp, Sl


Yango


Bmi Del Ecuador Compañía de Seguros De Vida


Depconsa


Technology holding


La Llave S.a. De Comercio


DLI Piper Martinez Beltran


Principaux dossiers


  • Represented Abbott Laboratorios del Ecuador in the tax court and the constitutional court in matters arising from the tariff classification of pharmaceutical products.
  • Advised Tiendas Industriales Asociadas Tia on a tax dispute with the IRS, successfully challenging the IRS’s interpretation of dividend payments for 2016 and 2017.
  • Represented Mitsui & Co. in an agreement to invest $360m in the largest shrimp farm in the world named Santa Priscila.

Lexvalor Abogados

Noted for its solid capabilities in tax planning and litigation, Lexvalor Abogados leverages its strong and growing links with legal and accounting firms in the Latin American region to increasingly work on international tax matters. Pharma, tech, tourism, financial, real estate and retail clients regularly turn to the firm for assistance with transfer pricing, tax compliance reviews and litigation before Ecuador’s Internal Revenue Service (SRI), municipal governments, and the Customs Administration. Tax litigation expert Carlos Coronel, who oversees the group’s judicial and administrative tax disputes work, is especially active in the oil and gas, financial, pharma, retail and service industries. Coronel heads the team alongside Paola Gachet, who is instrumental in the team’s tax matters relating to M&A, infrastructure projects and state planning. Founding partner Pablo Arias is another key point of contact for local and international clients seeking tax legal advice. Associate Víctor Chiriboga oversees the international area of the tax division, focusing on the application of double tax treaties and transactional work. Ana Belén Cadena and Danny Espinosa are also noted for their involvement in tax planning, and administrative and judicial proceedings.

Responsables de la pratique:

Carlos Coronel; Paola Gachet


Les références

‘Quick response, practical criteria, oriented towards problem solving.’

‘Carlos Coronel knows the subject very well, as well as the applicable legal framework. He is practical and assertive.’

‘Very professional team that has complete knowledge of the tax area, committed to the client in all processes.’

Principaux clients

Seguros Equinoccial


Gransolar


Avianca


La Fabril


Direct TV


Productos Avon


Corporación Favorita


Cervecería Nacional


Banco Internacional


Backus


Cooperativo de Ahorro y Crédito JEP


Rosaprima


Semper del Ecuador (CROCS Distributor)


LOGIKARD


ASTAP


Silvania


Pagoplux


Suzuki


Multicines


Principaux dossiers


  • Assisted Productos AVON Ecuador with several audit suits filed by the Customs Service.
  • Assisted Licores Nacionales y Extranjeros Liquors Cía. with an ICE assessment for the marketing of alcoholic beverages for the years 2006 and 2007.
  • Assisted several companies with investment contracts.

Pérez Bustamante & Ponce

Pérez Bustamante & Ponce acts for major local companies, including several players from the oil and gas, mining, financial, renewable energy, automotive, telecoms, food and beverage and pharma sectors, in tax planning and structuring, as well as administrative claims and judicial proceedings. Tax litigation is, indeed, a key area of strength for the group, which excels in cassation and constitutional tax actions. Practice head Juan Gabriel Reyes is a reference for tax planning and structuring matters in Ecuador. Carmen Simone-Lasso is a name to note for tax, customs and international trade matters, while Juan Francisco Carrasco-Velasco stands out for his experience in corporate tax issues and litigation before the tax authorities and judicial courts. Director Gianella Gallegos-Santos regularly assists with the challenging of tax assessments and tax refund applications, and Jeanette Jarrín focuses on tax planning and double taxation avoidance agreements.

Responsables de la pratique:

Juan Gabriel Reyes


Les références

The most outstanding thing is the service. The constant collaboration is great, and they are there when you need them.’

‘The team has experience in various fields, which allows it to provide global advice on a specific topic.’

‘Juan Francisco Carrasco has supported us in several litigations before the tax authorities. His experience in legal processes has allowed us to achieve positive results in several issues associated with audit processes carried out by the tax authority in Ecuador.’

Principaux clients

General Motors


Alcon Laboratories


Grupo Intercorp (Promart)


Otecel


Techint


Grupo Cobra (Spain)


Grupo Motta Internacional


Lundin


Holcim


Avianca Colombia


Principaux dossiers


  • Representing Avianca Colombia in a mediation process that seeks a refund of the withholding tax that was triggered by the payment of services rendered to Avianca Ecuador.
  • Represented Telefonica in a case in which the tax authority issued a VAT assessment for 2013 and demanded payment of VAT allegedly not charged by Otecel on transfers of telephones.

CorralRosales

With deep knowledge of tax and customs regulation, the practice at CorralRosales attracts instructions from a multitude of clients, most notably multinationals, seeking assistance with tax assessment procedures, due diligence processes and the tax aspects of corporate and financing transactions. In addition, the firm is singled out for its contentious expertise, and proficiency in international tax and customs matters. At the helm is customs expert Andrea Moya, who regularly advises international companies doing business in Ecuador and local companies looking to expand abroad. Xavier Rosales takes the lead on transactional work. Key support is offered by Fernanda Inga, who joined as senior associate from the Customs Authority in June 2023, and associate María José Flores, who excels in reimbursement claims and customs matters.

Responsables de la pratique:

Andrea Moya


Principaux clients

Payless ShoeSource


United Parcel Service


COPA Airlines


Ferrero


Omnibus (General Motors)


Location World


Nestlé


Raúl Coka Barriga Cia


Münich Re


Hannover Re


BAYERPROINTEC (INDRA)


PETROLIA (REPSOL)


La Tablita


Novopan del Ecuador


Millpolimerosericssonrobert Bosch


Principaux dossiers


  • Advised Petrolia Ecuador on a challenge against the settlement issued by the public company of hydrocarbons of Ecuador.
  • Advised Novopan del Ecuador on the analysis of the payment of contributions and initiation of claims for reimbursement before the tax agency.
  • Advised Millpolimeros on the analysis of the tax benefits applicable to a new investment to be made by the client.

Robalino

At Robalino, the tax team is sought out by major local and international clients from the oil and gas, pharma, automotive, retail, manufacturing and financial sectors, among others, for advice on the full gamut of matters, such as transfer pricing, customs issues, and international trade. Its broad service offering covers non-contentious and ligation matters, including cross-border transactions, international taxation issues and administrative proceedings. Leadership of the group is split between managing partner Javier Robalino Orellana, who assists with the tax aspects of multijurisdictional deals, and Emilio Aguayo, who specialises in tax litigation. Victor Murillo is another key contact for tax and customs mandates, while Karem Pesantez focuses on contentious processes.

Responsables de la pratique:

Javier Robalino Orellana; Emilio Aguayo


Les références

‘They have a good quality service. They are very friendly. We work directly with Víctor Murillo and he is always aware of our requirements.’

Principaux clients

Pluspetrol


Masgas


Spectrumecuador


Schlumberger


Consorcio Shushufindi


Shaya Del Ecuador


Oxialfarm Cia


Attenza Df Ecuador (Motta-internacional)


Toyota Del Ecuador


La Fabril


Valle Del Sol Valdesol Plus 22 Companies Member Of Expoflores


Eurofish


Transmarina


Ercoparts Trading (Subsidiary Ofcontinental Ag)


Colgate Palmolive Del Ecuador


Principaux dossiers


  • Advised PLUSPETROL B.V. on the administrative and judicial claim against the determination act for income tax of the fiscal year 2018.

Spingarn

Singled out by clients for its ‘in-depth knowledge of the law, as well as the excellent relationship it maintains with the regulator’, Spingarn's practice is adept in tax structuring, tax planning, customs matters and administrative proceedings. Managing partner Andrés Narváez, a ‘highly technical and knowledgeable‘ practitioner, is a key contact for tax disputes. He leads the practice alongside Diego Armas, who handles a mix of transactional, advisory and contentious tax matters. At the associate level, Javier Angulo stands out for his involvement in tax planning matters, while Kyra Rivera regularly advises telecoms, finance, retail and automotive clients on tax planning, asset structuring and risk assessment.

Responsables de la pratique:

Andrés Narváez; Diego Armas


Les références

‘The degree of involvement in the cases has been good. The in-depth knowledge of the law and disputes, as well as the excellent relationship it maintains with the regulator stands out. They maintain a transparent and ethical practice that is in line with our values.’

‘Andres Narváez is an excellent professional, highly technical and knowledgeable about our business and local and international legislation.’

‘In general, the members of the firm have demonstrated outstanding results with excellent performance. This gives us security and peace of mind.’

Principaux clients

Aceria del Ecuador C.A. Adelca


Grupo Sur Atlántida SLU


Holex Flower BV


Navent Group


Multitrabajos.com


JMI Group


PetroTal Corp


QBE Europe


Amassence


La Equidad Seguros


PayJoy Inc


Microfactorycapital-MFC


Pecksambiente


Ekippo (Grupo La Favorita)


Corporación Plusbrand del Ecuador C


Fonoa Technologies


Tecology


Buscalibre


Terrafertil


Ixion


Puntonet


Principaux dossiers


  • Assisted Diners Club with a restructuring initiative aimed at optimising its corporate framework and mitigating legal and regulatory risks.
  • Assisted Aekia with developing tailored strategies to improve its asset structure, mitigate tax liabilities, and ensure coherence in international transactions, safeguarding against legal complications.

Almeida Guzmán & Asociados

Almeida Guzmán & Asociados has a strong track record in advising local and foreign companies on tax planning, structuring and litigation before the administrative authorities and judicial courts. High-net-worth individuals also feature on its client roster, which is dominated by conglomerates from the insurance, food and beverage, life sciences, construction, agribusiness, automotive, retail, mining and energy sectors, among others. Practice head Diego Almeida Guzmán routinely advises on the tax elements of significant transactions. Other key individuals include Andrés Álvarez, who shines in administrative and judicial tax proceedings, attorney César Molina, whose areas of expertise include transfer pricing, and Ignacio Jijón, who offers key support in tax planning and litigation. The team was strengthened by the arrival of Rafaela Molina, who joined from Heka Law Firm in June 2023.

Responsables de la pratique:

Diego Almeida Guzmán


Les références

‘Almeida Guzman is our trusted adviser for all legal, regulatory and tax matters. Far superior to other firms we have worked with.’

‘Responsive, always available, deep knowledge of all areas required by the company.’

‘The practice is characterised by the closeness of its partners to our staff. The team is very open and knows our operation in depth. The analysis of tax operations both in Ecuadorian territory and those related to Germany and Mexico is profound.’

Principaux clients

Acciona Construcción – Consorcio Línea 1 Metro De Quito


Best Doctors Insurance


Sanofi Aventis


Grupo KFC


Maresa Corporation


Corporación Proauto


Ferrero del Ecuador


Avicola San Isidro – Avisid


GermanMotors


La Plata Mining


Principaux dossiers


  • Represented Acciona Construcción and Consorcio Línea 1 Metro de Quito in several tax litigation matters before local courts and administrative authorities.
  • Assisted Grupo KFC in negotiating, structuring, and perfecting several Investment Protection Agreements in order to maximise tax advantages offered by the law.
  • Represented Sanofi Aventis in two transfer pricing claims before the Ecuadorian Tax Courts working as co-counsel with the Colombian office of Baker and McKenzie.

Census Consultores

Census Consultores handles a wide range of tax matters, including litigation and advisory work. The group is well placed to provide advice on VAT and income tax, tax planning and administrative proceedings, and demonstrates extensive experience in tax compliance audits and tax due diligence for transactions. Practice head John Arias Izquierdo is an experienced tax lawyer, and José Arias Uzcátegui is also a key team member.

Responsables de la pratique:

John Arias Izquierdo


Les références

‘Professional and assertive. They go straight to the point and are very efficient in execution times.’

‘They master the subject and have expertise that is outstanding.’

‘They are very dedicated.’

Principaux clients

Consorcio


McDonalds – Arcgold del Ecuador


Aldo/Mango/ Parfois


Dole Ecuador – Logban Logística Bananera


Predial La Ponderosa Preponsa


IASA


CEPSA


Importadora Tomebamba


Marcimex


Surpapelcorp


Papelera Nacional


Productora Cartonera PROCARSA


Antonio Pino Icaza


Indurama Ecuador


Etafashion – Etatex


Telconet


Rolls Royce


Farmacias 911 – Gettareq


Licosa


Principaux dossiers


  • Advised Telconet on a reduction in the amount of tax payable through mediation and litigation.
  • Advised Predial La Ponderosa Preponsa on an administrative claim for undue payment before the Internal Revenue Service.
  • Advised Consorcio on a process opened by the Tax Authority.

Durini & Guerrero Abogados

Companies from the construction, financial, telecoms, oil and automotive sectors regularly turn Durini & Guerrero Abogados for assistance with a wide range of tax matters, including tax planning, transactions, tax audits, administrative proceedings and claims before the tax authorities. Leading the practice is Pablo Esteban Sánchez, a key port of call for telecoms, media and consumer goods clients seeking advice on tax planning. Carla Frías is proficient in VAT refund processes.

Responsables de la pratique:

Pablo Esteban Sánchez


Les références

‘The team I work with is committed. They help us to obtain the best results for the company. They always give us feedback on the activities they are developing and the actions that can be taken in the face of any adversity.’

‘We work with Pablo Sánchez and Carla Frías, experts in the tax field, both in income and municipal issues. With their guidance, we have been able to solve many problems that have arisen in the past.’

‘They are incomparable because the human quality and specialized treatment is unique. It is a team that is at the forefront, updated and highly specialised.’

Principaux clients

CNO


Banco Pichincha


Nipro Medical Corporation


Banco General Rumiñahui


IMS Internet Media Services Ecuador


Conecel


Drillcotec


Appdeuna


Emiliano Donoso


Donoso & Donoso


Peruzzi


Negocios Automotrices Neohyundai


Dinámica de Construcción Dinamiccomsa


Cooperativa de Ahorro y Crédito Cooprogreso


Corporación Codan


Ingesa


SIDERALSOFT


Tecfood Servicios de Alimentación


Principaux dossiers


  • Advising CNO on income tax for the 2017 tax year and payment of solidarity contribution tax on profits due to the earthquake that occurred in April 2016.
  • Advises Banco Pichincha C.A. on tax matters and tax planning and is currently involved in income tax litigation for the 2014 and 2015 tax years.
  • Representing Nipro Medical Corporation in a tax lawsuit.

Meythaler & Zambrano Abogados

Highlighted for its 'unique combination of specialised experience, exceptional technical skills and an unwavering commitment to excellence in client service', the tax group at Meythaler & Zambrano Abogados acts for a diverse client base comprised of companies from the pharma, construction, food, TMT, and manufacturing sectors, among others. Contentious matters before customs authorities, the SRI and judicial courts are a key area of strength for the group. Gabriel Pinto leads the team, bringing a strong knowledge of taxation and customs regulation, particularly related to the pharmaceutical industry. Key support is offered by Emilia Larco, who focuses on tax law matters.

Responsables de la pratique:

Gabriel Pinto


Les références

‘As a team, constant monitoring and effective communication make the processes flow better, allowing me to know how cases progress not only with technical language but also with an explanation that is easy to understand. This allowed us to make decisions in advance and develop a strategy that paid off and we closed the case on the best terms.’

‘MZ’s practice is distinguished by its innovative and highly collaborative approach to addressing clients’ legal challenges. In-house counsel should know that the team has a unique combination of specialised experience, exceptional technical skills and an unwavering commitment to excellence in client service.’

‘This team stands out for its ability to adapt quickly to market changes and for its proactive use of technology to improve efficiency and service quality. This practice stands out not only for its top-tier legal expertise but also for its forward-thinking approach and commitment to continuous improvement.’

Apolo Abogados

Apolo Abogados‘ tax and customs team operates predominantly in the fisheries, maritime and ports sectors, often advising on tax efficiency matters and the tax elements of corporate transactions. The practice is under the leadership of tax expert Carlos Andres Arosemena Ortega.

Responsables de la pratique:

Carlos Andres Arosemena Ortega


Les références

‘Extensive knowledge of the sector in which our company operates.’

Principaux clients

Promarisco


Inbalnor


Seafman sociedad ecuatoriana de alimentos y frigorificos manta


Eurofish


Inarpi


Calademar


Negocios Industriales Real nirsa


Tecnica Y Comercio De La Pesca


Agripac


Biomar


Principaux dossiers


  • Represented Eurofish in a lawsuit against the National Customs Service of Ecuador, challenging a 2021 settlement that questioned the appropriateness of a tax credit granted in 2014 for certain exports.
  • Assisted Agripac S.A. with securing a ruling from the SRI and a technical statement from the Ministry of Production, affirming a soybean meal’s use as animal feed, thereby validating the 0% VAT application.
  • Assisted Calademar with securing an investment contract which not only ensured tax benefits but also protected the land’s property rights for ongoing investments.

Noboa, Peña & Torres, Abogados

Noboa, Peña & Torres, Abogados excels in the tax structuring of new ventures and investments. The group is especially active in advising on the tax aspects of M&A and corporate restructurings, but also demonstrates robust knowledge of transfer pricing matters. Founding partner Patricio Peña Romero oversees the tax practice, which acts for clients, including start-ups and multinationals, from the industrial, construction, and agribusiness sectors. Verónica Zambrano Arboleda is a name to note for tax matters at the associate level.

Responsables de la pratique:

Patricio Peña Romero


Principaux clients

Mega Santa Maria


Olam Ecuador


Soderal Sociedad de Destilación de Alcoholes


Cedal Durán


Corporación Ecuatoriana de Aluminio


Importación y Distribución Shoestatiana


Roddome Pharmaceutical


Barry Calebaut Ecuador


Transfuel Group


Pino Elizalde Abogados

The tax practice at Pino Elizalde Abogados is particularly skilled at identifying the tax implications of corporate transactions. The group also assists local and international companies, including names from the real estate, services, agribusiness, food and beverage, and automotive sectors, as well as individuals with tax optimisation matters. Montserrat Sánchez Álvarez directs the tax practice, focusing on tax consulting mandates. Daniel Pino is also noted for his involvement in the tax department.

Responsables de la pratique:

Montserrat Sánchez Álvarez


Les références

‘I had the experience of working with Pino Elizalde and I liked the advice they gave us on the services we required. The whole team was in tune to advise the client and gave us the right solutions to what we needed to achieve.’

‘They are people who are always willing to help and are always available. I had the opportunity to work closely with Montse Sanchez and Daniel Pino. They are professionals who are passionate about their profession and dedicated to solving the situations that clients require.’

Principaux clients

Odema


Roberto Jarrín


Assistecviajes


Fernando Castellon


Frutadeli


LABORATORIOS DR. A. BJARNER


Principaux dossiers


  • Provided Assistecviajes with assistance in a municipal procedure for the declaration of prescription and cancellation of tax certificates issued by the tax department of the Municipality of Guayaquil.
  • Advised Odema on the tax implications associated with the loan agreement between the client and Odema, a company incorporated in Ecuador.
  • Advised Frutadeli on the optimisation of its tax situation, implementing strategic initiatives to enhance overall tax efficiency and compliance across corporate entities.

Solines y Asociados

Solines y Asociados is home to 'a group of highly qualified professionals' who advise an array of clients, most notably exporters and importers operating in the flower farming, textile and manufacturing industries, on tax and customs matters. The group stands out for its experience in customs disputes, but is also well positioned to assist with lawsuits before the tax authorities and courts, tax benefits and exemptions, special contribution refunds and international taxation issues. Senior associate Yael Fierro - 'a dedicated, technical and very efficient lawyer' - leads the practice which also features Nicole Saltos, a name to note for tax litigation, tax audits and administrative proceedings.

Responsables de la pratique:

Yael Fierro


Les références

‘A very efficient team and above all very gentle always in their treatment and very helpful with the requirements and doubts. Excellent lawyers.’

‘A proactive team that generates solutions and faithfully represents the interests of the client. It presents clear ideas and builds a bridge of trust between the various parties involved in the processes.’

‘The tax team of Solines & Asociados Abogados is a group of highly qualified professionals who are characterised by their personalised treatment to the client and their good predisposition to provide solutions to their clients. In addition, they are highly technical lawyers who identify opportunities for improvement and preventive actions for the company. They stand out for their personalised and warm attention.’

Principaux clients

Texlafayette


Productos Autoadhesivos Arclad


Comercializadora Internacional Ciecopalma


Constructora Josanc


Hilsea Investments Limited


Mac-access


Agricola El Rosario Agrirose


Icapeb


Ecuainsetec


Principaux dossiers


  • Represented Productos Autoadhesivos Arclad in a lawsuit challenging a resolution of the Internal Revenue Service, which denied an appeal for review of a foreign currency outflow tax for the 2018 tax year resulting from the importation of self-adhesive paper and self-adhesive plastic film, considered raw material to produce labels.
  • Acted for Comercializadora Internacional Ciecopalma in a lawsuit filed to settle a dispute between the plaintiff and the national tax administration (Servicio de Rentas Internas), based on a forced execution process with cautionary measures.
  • Advised Hilsea Investments on tax compliance issues and future tax obligationsbefore the tax authorities.