Propuesta metodológica para la evaluación del régimen de precios de transferencia en transacciones con partes relacionadas del sector camaronero.

Abstract

This methodological proposal is based on the need to know the incidence of transfer prices in the exports of the shrimp sector in Ecuador, considering the impact that could have those transactions that are not in accordance with good market practices and that do not comply with the principle of full competition in negotiations with related parties abroad as well as locally. Therefore, a methodological guide is established based on the use of designs, types of research and the respective techniques and instruments for the collection of information. From the use of the methodological proposal, the following findings were determined. Transfer prices are not an exact science, considering that for analysis it is necessary to use different sources of information to determine comparable companies. In relation to foreign transactions, the existence of income tax adjustments is evaluated, which is common among intercompany transactions. The applicable recommendations for the shrimp sector to demonstrate compliance with full competence are: (a) to carry out internal verifications of transfer prices regardless of being obliged; (b) to keep an adequate control of the operations carried out between related parties in accordance with the information requirements issued by the tax administration; (c) to carry out an adequate and reliable justification on the use of the methods for different operations carried out, in addition to the choice of the indicators used in applicable cases; (d) to adapt to the good market practices in each of the transactions carried out.