J. Law Epistemic Stud. (2026) 4: e204
https://doi.org/10.5281/zenodo.22899670
ISSN 3091-1575
ORIGINAL ARTICLE
Tax Mediation in Ecuador and Challenges for Its
Application from the Perspective of Citizen Knowledge
in Esmeraldas
Mediación tributaria en Ecuador y desafíos para su aplicación desde el conocimiento
ciudadano en Esmeraldas
Giannella Haz-Guevara Teresa N. López-Macías
© The Author(s) 2026
Abstract This study analyzes tax mediation in Ecuador from
a legal and institutional perspective and examines the level
of knowledge among a group of citizens in the province of
Esmeraldas regarding this alternative mechanism for
resolving tax disputes. The objective was to examine its
regulatory scope, the main difficulties affecting its
application, and participants’ knowledge of its operation
and access channels. A mixed, descriptive, and analytical
approach was used, combining legal-documentary and
bibliographic review with a survey administered to 116
residents of Esmeraldas aged 18 to 50. The results show
that 52.6% reported knowing the concept of tax mediation;
however, 60.3% did not know the procedure for initiating
it, and 57.8% could not identify the institutional channel
through which it could be submitted. Overall, the findings
reveal a gap between conceptual knowledge and
procedural and institutional knowledge. The study
concludes that tax mediation has legal support and
potential as a complementary mechanism for managing tax
disputes, although its consolidation requires greater
dissemination, operational clarity, and stronger
institutional access channels.
Keywords tax mediation; tax disputes; tax settlement;
alternative dispute resolution; Ecuador.
Resumen La investigación analiza la mediación tributaria en
Ecuador desde su marco jurídico e institucional y examina el
nivel de conocimiento de un grupo de ciudadanos de la
provincia de Esmeraldas sobre este mecanismo alternativo
de solución de controversias fiscales. El objetivo fue estudiar
su alcance normativo, las principales dificultades para su
aplicación y el conocimiento de los participantes respecto de
su funcionamiento y vías de acceso. Se empleó un enfoque
mixto, descriptivo y analítico, que combinó revisión
jurídico-documental y bibliográfica con una encuesta
aplicada a 116 personas de 18 a 50 años residentes en
Esmeraldas. Los resultados muestran que el 52,6 %
manifestó conocer el concepto de mediación tributaria; sin
embargo, el 60,3 % desconocía el procedimiento para
iniciarla y el 57,8 % no identificaba la instancia ante la cual
podía presentarse. En conjunto, los hallazgos revelan una
brecha entre el conocimiento conceptual y el conocimiento
procedimental e institucional. Se concluye que la mediación
tributaria cuenta con respaldo jurídico y potencial como vía
complementaria para la gestión de controversias, aunque su
consolidación exige mayor difusión, claridad operativa y
fortalecimiento de los canales institucionales de acceso.
Palabras clave mediación tributaria; conflictos fiscales;
transacción tributaria; mecanismos alternativos; Ecuador
Giannella Haz-Guevara Teresa N. López-Macías
Received: 10 July 2026 / Accepted: 20 August 2026 / Published online: 8 September 2026
Abstract This study analyzes tax mediation in Ecuador from
Keywords tax mediation; tax disputes; tax settlement;
Resumen La investigación analiza la mediación tributaria en
Palabras clave mediación tributaria; conflictos fiscales;
How to cite
Haz-Guevara, G., & López-Macías, T. N. (2026). Tax Mediation in Ecuador and Challenges for Its Application from the Perspective of
Citizen Knowledge in Esmeraldas. Journal of Law and Epistemic Studies, 4, e204. https://doi.org/10.5281/zenodo.22899670
Giannella Haz-Guevara
Centro de Mediación “Esmeraldas por la Paz”, Esmeraldas, Ecuador.
Teresa N. López-Macías
Centro de Mediación de la Función Judicial del Ecuador, Manabí, Ecuador.
Giannella Haz-Guevara
Centro de Mediación "Esmeraldas por la Paz"
Esmeraldas, Ecuador.
Teresa N. López-Macías
Centro de Mediación de la Función Judicial del Ecuador
Manabí, Ecuador.
Giannella Haz-Guevara
1
Teresa N. López-Macías
2
Giannella Haz-Guevara
1 Centro de Mediación "Esmeraldas por la Paz",
Esmeraldas, Ecuador.
2 Centro de Mediación de la Función Judicial
del Ecuador, Manabí, Ecuador.
J. Law Epistemic Stud. (2026) 4: e204
Introduction
The tax system constitutes one of the fundamental pillars for
the financial sustainability of the State and the implementation
of public policies aimed at collective well-being. In Ecuador,
the Constitution of the Republic establishes that the tax
regime must be governed by the principles of generality,
progressivity, efficiency, administrative simplicity, equity,
and transparency, with the aim of ensuring adequate public
revenue collection and taxpayer compliance with fiscal
obligations (Asamblea Constituyente del Ecuador, 2008).
Nevertheless, the dynamics of the legal-tax relationship
frequently generate disputes between the tax administration
and taxpayers, arising from assessment, auditing, or
regulatory interpretation processes. These disputes are usually
channeled through administrative or judicial procedures that,
in many cases, are lengthy, costly, and complex, which
highlights the need to explore alternative mechanisms capable
of enabling more efficient resolution of tax disputes.
In comparative tax law, recent literature has emphasized that
alternative dispute resolution mechanisms can provide
complementary avenues to traditional litigation, particularly in
proceedings characterized by duration, technical complexity,
and associated costs (Haslehner et al., 2023; Moosa, 2023).
From a European perspective, alternative resolution of tax
disputes has also gained relevance as a complementary
instrument to traditional appeal mechanisms, particularly in
contexts characterized by increasing regulatory and
cross-border complexity (Richelle, 2023).
In Ecuador, settlement in tax matters was expressly
incorporated by the Organic Law for Economic Development
and Fiscal Sustainability after the COVID-19 Pandemic,
which added to the Tax Code a specific regime for resolving
certain disputes related to the determination or collection of
tax obligations. Its implementation through mediation makes
it possible to explore consensual solutions within the
applicable legal limits and the matters that may be subject to
settlement (Asamblea Nacional del Ecuador, 2021; Servicio
de Rentas Internas, 2022a, 2022b).
Despite this regulatory recognition, the practical application
of the mechanism faces challenges. Specialized literature
points to interpretive and operational difficulties in defining
matters that may be settled, insufficient institutional
dissemination, resistance from certain actors, and a legal
culture still oriented toward litigation (Romero Jarrín, 2025).
These conditions may limit the effective use of mediation
even when a legal basis authorizes it.
In particular, factors such as interpretive and operational
difficulties in delimiting matters susceptible to settlement,
limited dissemination of the mechanism, institutional
resistance from some administrative actors, and a weak
negotiation culture in tax matters have been identified as
directly affecting its limited use (Romero Jarrín, 2025).
Likewise, the very nature of tax credit, traditionally regarded
as unavailable to the public administration, has generated
doctrinal debate regarding the scope and limits of settlement
and mediation in tax matters.
From a comparative perspective, the effectiveness of
alternative mechanisms in tax matters does not depend
exclusively on their regulatory recognition, but also on the
existence of procedural safeguards, institutional accessibility,
and conditions that allow taxpayers to participate in an
informed manner (Moosa, 2024).
Tax mediation is closely linked to settlement, since
agreements may only concern aspects that are legally open to
negotiation. Consequently, the clarity of regulatory limits and
the manner in which they are applied influence the real
possibilities of reaching agreements. Recent studies have
related the delimitation of matters open to settlement to the
agreements reached and the revenue derived from these
procedures, while identifying doctrinal and institutional
challenges that remain in the Ecuadorian context (García
Vallejo et al., 2025; Jarrín & de la Vega, 2026).
In this context, it is relevant to examine not only the legal
structure of the mechanism, but also the level of knowledge
possessed by its potential users. The formal existence of an
alternative pathway does not guarantee its use if taxpayers do
not know how it operates, where it can be initiated, or what its
limits are. Therefore, the objective of this study was to
analyze the legal and institutional scope of tax mediation in
Ecuador, identify the main challenges noted in the literature,
and examine participants’ knowledge regarding its concept,
procedure, and access channels.
Methodology
This study was conducted using a mixed methodological
approach, combining legal-documentary analysis with the
collection of empirical information through a survey. This
methodological strategy made it possible to examine tax
mediation in Ecuador from two complementary dimensions:
on the one hand, the study of the regulatory and doctrinal
framework governing its application and, on the other, the
perceptions and knowledge of the population regarding this
alternative mechanism for resolving tax disputes.
Regarding the type of research, the study follows a descriptive
and analytical design. The descriptive component made it
possible to characterize the regulatory and institutional
development of tax mediation within the Ecuadorian legal
system, while the analytical approach facilitated a critical
examination of the legal, doctrinal, and institutional elements
that determine its functioning and effectiveness. This process
made it possible to identify the principal legal provisions
governing tax mediation, as well as its relationship with tax
settlement and alternative dispute resolution mechanisms in
tax matters.
The study applied the legal-dogmatic method, aimed at the
systematic analysis and interpretation of the legal rules
governing tax mediation within the Ecuadorian tax system.
This method made it possible to examine the regulatory
structure supporting the use of alternative dispute resolution
mechanisms in the tax field, as well as their relationship with
the constitutional principles governing the tax regime.
Complementarily, the analytical-synthetic method was used,
through which the phenomenon of tax mediation was broken
down into its main conceptual, regulatory, and institutional
J. Law Epistemic Stud. (2026) 4: e204
components and subsequently integrated into a systematic
interpretation that makes it possible to understand its scope
and functioning within the Ecuadorian legal system.
The research also incorporated a specialized bibliographic
review through the consultation and analysis of academic
literature, scientific articles, university theses, institutional
documents, and current regulations related to tax mediation
and tax settlement. The selection of these sources responded
to criteria of thematic relevance, currency, and academic
rigor, which made it possible to construct a solid theoretical
framework for analyzing the phenomenon under study. Based
on this documentary review, the main existing doctrinal
debates regarding the effectiveness of tax mediation were
identified, as well as the legal and institutional factors
influencing its implementation within the Ecuadorian tax
system.
As a complement to the documentary analysis, an empirical
component was incorporated using a survey designed to
identify participants’ level of knowledge about tax mediation.
The questionnaire consisted predominantly of closed
dichotomous questions (yes/no) and, in certain items, an
additional category of partial knowledge. The instrument
made it possible to distinguish general knowledge of the
mechanism from more specific aspects related to its procedure
and the institutional channels available for its use.
The instrument was administered digitally during August
2023 to 116 participants aged 18 to 50 residing in the province
of Esmeraldas, Ecuador. Given the territorial scope of the
study, the results are interpreted as an approximation of the
knowledge observed in this group of participants and not as an
estimate representative of the entire Ecuadorian population.
The information obtained was organized through tabulation
and descriptive analysis of frequencies and percentages. This
strategy made it possible to identify trends in the responses
and to compare conceptual knowledge of tax mediation with
knowledge related to its procedure and the institutions
available for initiating it.
The methodological process was carried out in three main
phases. In the first phase, regulatory and bibliographic sources
were collected and analyzed in order to establish the
conceptual and legal framework of tax mediation in Ecuador.
In the second phase, the survey instrument was applied and
the information obtained was systematized, allowing the
collection of empirical data related to social perceptions of the
mechanism. Finally, in the third phase, the results were
integrated and analyzed by contrasting the empirical findings
with the doctrinal and regulatory analysis developed in the
study.
Results and discussion
The first dimension analyzed was general knowledge of tax
mediation. Figure 1 presents the responses of the 116
participants residing in the province of Esmeraldas and
provides a first approximation of their degree of familiarity
with the mechanism.
Figure 1. Level of knowledge about tax mediation among surveyed
participants
Note: The figure shows the results obtained from a survey administered to 116
participants. Responses were structured into three categories: “Yes,” “No,” and
“Some knowledge,” in order to identify the level of knowledge about tax mediation.
The 52.6% of participants stated that they knew what tax
mediation is, while 46.6% indicated that they did not know it
and a minimal proportion reported partial knowledge.
Although there is a slight majority declaring familiarity with
the concept, the results show that lack of knowledge remains
considerable within the group studied.
This result is relevant because the regulatory recognition of an
alternative mechanism does not by itself ensure its
appropriation by potential users. In this sense, institutional
dissemination and the availability of understandable
information constitute necessary conditions for mediation to
be effectively considered as an alternative in the event of a tax
dispute (Romero Jarrín, 2025).
The empirical evidence reveals a gap between regulatory
recognition of the mechanism and its social appropriation.
This result is consistent with Romero Jarrín (2025), who
argues that the effectiveness of tax mediation depends not
only on its legal design, but also on the level of understanding
taxpayers have of how it operates. Consequently, the formal
existence of the mechanism does not by itself guarantee its
effective use if it is not accompanied by sustained institutional
dissemination and training strategies.
The second dimension examined knowledge of the procedure
for initiating tax mediation. This variable makes it possible to
distinguish between knowing that the mechanism exists and
having sufficient information to use it in practice. The results
are presented in Figure 2.
Figure 2. Knowledge of the procedure for initiating tax mediation
Note: The figure presents the results of a survey administered to 116 people aged 18
to 50 residing in the province of Esmeraldas, Ecuador. The question assessed
whether participants knew the procedure for initiating tax mediation, using a
dichotomous response scale (yes/no).
J. Law Epistemic Stud. (2026) 4: e204
The 60.3% of participants stated that they did not know how
tax mediation is initiated, compared with 39.7% who said they
knew the procedure. The difference compared with the
general knowledge observed in Figure 1 shows that familiarity
with the concept does not necessarily translate into operational
knowledge.
This result is consistent with studies linking taxpayer
education and awareness programs with a greater willingness
to use alternative dispute resolution mechanisms in tax
disputes (Mburu et al., 2026). The observed gap therefore
suggests that institutional outreach should explain not only
what mediation is, but also the steps required to access and
use it.
The third dimension focused on determining whether
participants could identify the institution or institutional
channel through which tax mediation may be initiated. This
aspect complements the procedural analysis because effective
access to the mechanism requires knowing not only what it
consists of, but also where it can be brought. The results are
presented in Figure 3.
Figure 3. Knowledge of the institution or channel through which tax
mediation may be initiated
Note: The figure assessed whether participants knew before which institution or
institutional channel tax mediation can be initiated. Responses were structured using
a dichotomous scale (yes/no).
The 57.8% of participants indicated that they did not know the
institution or institutional channel for initiating tax mediation,
while 42.2% stated that they did. This result confirms that
operational and institutional knowledge is lower than general
conceptual knowledge and constitutes a potential barrier to
access to the mechanism.
Comparative literature reinforces this interpretation by
indicating that effective access to alternative mechanisms
requires understandable rules, adequate information, and
institutional channels that are clearly identifiable to taxpayers
(Moosa, 2024).
Considered together, the results of Figures 1, 2, and 3 show a
consistent pattern: conceptual knowledge of tax mediation is
greater than the procedural and institutional knowledge
required to use it. This constitutes the main empirical finding
of the study and reveals a gap between recognition of the
mechanism and the informational conditions necessary for
access to it.
From a doctrinal perspective, mediation and tax settlement
may offer advantages over traditional litigation in certain
disputes, especially because of their orientation toward
dialogue, the search for agreements, and the possibility of
reducing certain costs associated with prolonged proceedings.
However, these advantages should be understood as potential
and conditioned by the nature of the dispute, the limits
inherent in public tax law, and the applicable institutional
design (Galindo Cardona, 2001; Moosa, 2023; Sa’adah et al.,
2024).
Based on the doctrinal and regulatory analysis developed in
the specialized literature, several factors were identified that
help explain the limited application of tax mediation within
the Ecuadorian fiscal system. Although the legal system has
incorporated mechanisms designed to promote consensual
solutions between the tax administration and taxpayers,
academic evidence suggests that their practical
implementation faces several structural limitations. These
include insufficient dissemination of the mechanism,
regulatory restrictions associated with tax settlement, and the
persistence of a legal culture oriented toward litigation as the
principal means of resolving tax disputes. Table 1 summarizes
the principal factors identified in recent literature as affecting
the limited use of tax mediation in Ecuador.
Table 1. Factors identified in the literature that affect the limited use of
tax mediation in Ecuador
Identified factor Description Impact on tax mediation
Insufficient
institutional
dissemination
Limited socialization of the
mechanism within the tax
system and among taxpayers.
Reduces citizens’ knowledge
about the existence and
operation of tax mediation.
Regulatory and
administrative
restrictions
Rules related to tax
settlement that delimit the
aspects that may be agreed
between the parties.
Limits the scope of
agreements that can be
reached within mediation
processes.
Legal culture
oriented toward
litigation
Predominance of legal
practices based on
contentious resolution of tax
disputes.
Discourages the use of
alternative dispute resolution
mechanisms.
Note: Author’s own elaboration based on the analysis of specialized literature on
mediation and tax settlement in Ecuador (Romero Jarrín, 2025; García Vallejo et al.,
2025; Jarrín & de la Vega, 2026; Angulo Pachano et al., 2026; Palacios Palacios,
2025).
The information summarized in the table shows that the
limited use of tax mediation identified in the literature results
from the interaction of institutional, regulatory, and cultural
factors. Among them, insufficient dissemination is
particularly important, as it reduces the possibility that
taxpayers and legal practitioners understand the functioning of
and conditions for accessing the mechanism (Romero Jarrín,
2025).
Second, the regulatory development of tax mediation is
closely linked to the regulation of tax settlement, which means
that agreements reached within mediation processes must
comply with the limits established by tax legislation. Several
studies have noted that a lack of regulatory clarity regarding
matters open to settlement can restrict the parties’ room for
negotiation and reduce the effectiveness of mediation as a tax
dispute resolution tool (García Vallejo et al., 2025; Jarrín & de
la Vega, 2026).
The persistence of a legal culture oriented toward litigation is
another relevant factor. Preference for traditional
administrative and judicial avenues may hinder the
incorporation of consensual mechanisms even when they are
formally recognized (Angulo Pachano et al., 2026).
J. Law Epistemic Stud. (2026) 4: e204
Taken together, these factors show that consolidating tax
mediation does not depend on a single reform. Clarity in
applying the limits of settlement, accessibility of institutional
channels, and dissemination aimed at taxpayers and
professionals must work in a complementary manner to
encourage its use (Jarrín & de la Vega, 2026; Angulo Pachano
et al., 2026).
From a legal and institutional perspective, tax mediation can
function as a complementary avenue for managing certain tax
disputes. Its potential usefulness lies in providing a space for
dialogue and negotiation within the limits of tax settlement,
without replacing administrative or judicial avenues when
these are necessary (Congreso Nacional del Ecuador, 2006).
Among the potential effects identified in the literature is the
reduction of certain costs and burdens associated with
prolonged contentious proceedings. However, the magnitude
of that effect depends on the number of cases susceptible to
settlement, effective access to the mechanism, and
institutional capacity to process them adequately (Angulo
Pachano et al., 2026).
A potential contribution to collection efficiency has also been
suggested when agreements facilitate compliance with
obligations within the legal framework. This relationship
should not be assumed automatically: recent studies suggest
that the clarity of rules applicable to settlement may influence
the agreements reached and their revenue effects (Alvarado
Maldonado, 2022; Jarrín & de la Vega, 2026).
From the perspective of the tax legal framework, the
possibility of implementing alternative dispute resolution
mechanisms is linked to the principles guiding the Ecuadorian
tax system, including administrative efficiency and proper
management of public resources. The Tax Code establishes
the regulatory bases governing the relationship between the
tax administration and taxpayers, providing the legal
framework within which mechanisms can be developed to
resolve disputes in a more efficient and less confrontational
manner (Código Tributario, 2005). In this sense, tax mediation
is presented as a tool that can help strengthen the relationship
between the parties by promoting solutions based on dialogue
and institutional cooperation.
Nevertheless, for tax mediation to fully achieve its potential
within Ecuador’s fiscal system, it is necessary to strengthen
the institutional framework and dissemination strategies for
the mechanism. Several studies have pointed out that one of
the main challenges to consolidating alternative dispute
resolution mechanisms in Ecuador lies in the limited
understanding and use of these instruments by the actors
involved in legal disputes (Angulo Pachano et al., 2026). In
tax matters, this situation is aggravated by the technical
complexity of fiscal regulations and the persistence of legal
practices traditionally oriented toward litigation.
In this context, specialized literature highlights the importance
of consolidating institutional policies aimed at strengthening
the application of tax mediation within the fiscal system.
These measures include clarifying the regulatory limits of tax
settlement, strengthening the institutional procedures
governing mediation, and promoting training strategies aimed
at both public officials and taxpayers (Palacios Palacios,
2025). The adoption of these actions would contribute to
consolidating tax mediation as an effective tool for managing
tax disputes, helping improve administrative efficiency,
strengthen legal certainty, and promote a more cooperative
relationship between the tax administration and taxpayers.
Limitations of the study
The empirical component of the study measures participants’
self-reported knowledge rather than the actual effectiveness of
tax mediation. Therefore, the data do not directly determine
the number of agreements reached, the duration of procedures,
the effective reduction of litigation, or the effects on tax
collection. In addition, the sample is limited to 116
participants residing in the province of Esmeraldas, so the
results should not be generalized to all Ecuadorian taxpayers.
Future research could incorporate administrative records,
mediation case files, and broader territorial samples to
evaluate the functioning of the mechanism using objective
indicators.
Conclusions
The research made it possible to analyze tax mediation in
Ecuador from two complementary dimensions: its
legal-institutional configuration and participants’ knowledge
of its existence and forms of access. The regulatory analysis
shows that mediation has a legal basis linked to tax settlement,
but its application is conditioned by the limits established for
matters susceptible to agreement.
The empirical results revealed a clear gap between conceptual
knowledge and operational knowledge. Although 52.6%
stated that they knew what tax mediation is, 60.3% did not
know the procedure for initiating it and 57.8% could not
identify the corresponding institution or institutional channel.
Consequently, the principal deficit observed is not limited to
dissemination of the concept, but extends to the information
necessary to use the mechanism in practice.
This gap supports the conclusion that strengthening tax
mediation requires dissemination strategies aimed at
explaining, in an accessible manner, its requirements,
procedure, limits, and access channels. The existence of
regulation is insufficient when potential users do not have
clear information for activating the mechanism.
The literature analysis also identifies regulatory, institutional,
and cultural factors that may restrict its use. These include the
need for clear application of the limits of tax settlement,
insufficient dissemination, and the persistence of legal
practices oriented toward litigation. Addressing these issues
requires complementary measures rather than isolated
regulatory reforms.
Tax mediation may constitute a complementary avenue for
certain tax disputes and provide spaces for consensual
resolution; however, this study does not measure its
effectiveness using objective indicators of agreements,
duration, litigation, or tax collection. Accordingly, any effect
on administrative or collection efficiency should be
understood as a potential supported by the legal framework
and reviewed literature, rather than as a result demonstrated
J. Law Epistemic Stud. (2026) 4: e204
by the survey.
In summary, the consolidation of tax mediation in Ecuador
depends on combining legal certainty, operational clarity,
institutional strengthening, and tax education. The central
finding of the study - the distance between knowing the
concept and knowing how to use it - provides a concrete basis
for guiding dissemination actions and future research on the
actual performance of the mechanism.
References
Alvarado Maldonado, S. I. (2022). Importancia jurídica y procesal de la
transacción. Revista Científica FIPCAEC, 7(3), 116–133.
https://www.fipcaec.com/index.php/fipcaec/article/view/596
Angulo Pachano, B. M., Barzola Reyes, J. D., & Campos Cárdenas, F.
(2026). La eficacia de los mecanismos alternativos de solución de
conflictos en Ecuador: Un estudio crítico. Revista Lex, 9(32), 265–280.
https://doi.org/10.33996/revistalex.v9i32.455
Asamblea Constituyente del Ecuador. (2008). Constitución de la
República del Ecuador. Registro Oficial No. 449, 20 de octubre de 2008.
https://www.asambleanacional.gob.ec/es/contenido/constitucion-de-la-re
publica-del-ecuador-2008-reformada
Asamblea Nacional del Ecuador. (2021). Ley Orgánica para el
Desarrollo Económico y Sostenibilidad Fiscal tras la Pandemia
COVID-19. Tercer Suplemento del Registro Oficial No. 587, 29 de
noviembre de 2021. https://www.asambleanacional.gob.ec/es/multimedio
s-legislativos/75236-ley-organica-para-el-desarrollo
Código Tributario. (2005). Codificación No. 2005-09. Suplemento del
Registro Oficial No. 38, 14 de junio de 2005 (versión consultada con
reformas hasta el 20 de diciembre de 2023). https://www.sri.gob.ec/o/sri-
portlet-biblioteca-alfresco-internet/descargar/a27254d4-ec82-46d7-a85d-
504b508c3503/Codigo_Tributario_20122023.pdf
Congreso Nacional del Ecuador. (2006). Ley de Arbitraje y Mediación.
Codificación 14. Registro Oficial No. 417, 14 de diciembre de 2006. http
s://www.funcionjudicial.gob.ec/resources/pdf/Ley%20de%20Arbitraje%
20y%20Mediaci%C3%B3n%20final.pdf
Galindo Cardona, Á. (2001). Origen y desarrollo de la solución
alternativa de conflictos en Ecuador. Iuris Dictio, 2(4).
https://doi.org/10.18272/iu.v2i4.561
García Vallejo, P. E., Briones Cervantes, R. J., & Cevallos Zambrano, E.
C. (2025). La transacción como mecanismo de solución alternativa de
conflictos tributarios en Ecuador: Aplicabilidad y desafíos [Trabajo de
titulación de pregrado]. Universidad San Gregorio de Portoviejo,
Repositorio Institucional.
http://repositorio.sangregorio.edu.ec/handle/123456789/3868
Haslehner, W., Lyons, T., Kofler, G., Pantazatou, K., & Rust, A. (Eds.).
(2023). Alternative dispute resolution and tax disputes. Edward Elgar
Publishing. https://doi.org/10.4337/9781803920382
Jarrín, F. A. R., & de la Vega, D. A. G. (2026). Transacción tributaria,
claridad y amplitud: Efectos sobre acuerdos y recaudación en la
mediación (Ecuador). Eirene Estudios de Paz y Conflictos, 9(16),
253–277. https://doi.org/10.62155/eirene.v9i16.341
Mburu, G. W., Gitonga, D., & Kirui, D. (2026). Taxpayer education and
adoption of alternative dispute resolution in tax disputes moderated by
trust in tax authorities among medium and large-sized enterprises in
Nairobi-East District, Kenya. Journal of Finance and Accounting, 6(2),
53–71. https://doi.org/10.70619/vol6iss2pp53-71-771
Moosa, F. (2023). Review of the new alternative dispute resolution
process for tax disputes. Journal of South African Law, 2023(4),
660–680. https://doi.org/10.47348/TSAR/2023/i4a4
Moosa, F. (2024). A taxpayer’s right to fair alternative dispute resolution.
Journal for Juridical Science, 49(2), 69–100.
https://doi.org/10.38140/jjs.v49i2.8747
Palacios Palacios, A. F. (2025). La mediación en materia tributaria frente
a los principios de eficiencia y suficiencia recaudatoria: Especial
referencia al régimen impositivo nacional [Tesis de maestría,
Universidad Andina Simón Bolívar, Sede Ecuador]. Repositorio
Institucional UASB. http://hdl.handle.net/10644/10385
Richelle, I. (2023). Alternative dispute resolution in the European Union.
In The Oxford handbook of international tax law (pp. 697–728). Oxford
University Press.
https://doi.org/10.1093/oxfordhb/9780192897688.013.42
Romero Jarrín, F. A. (2025). Mediación tributaria en el Ecuador: Análisis
jurídico y empírico de los factores que inciden en su eficiencia como
método de solución de conflictos fiscales [Tesis doctoral, Universidad
Autónoma de Nuevo León]. Repositorio Digital UANL.
http://eprints.uanl.mx/31069/1/1080240377.pdf
Sa’adah, N., Ispriyarso, B., Wibawa, K. C. S., Wibawa, L. K. P. S., &
Septenta, M. I. (2024). Feasibility analysis of implementing alternative
dispute resolution in tax dispute settlement in Indonesia. Pandecta
Research Law Journal, 19(2).
https://doi.org/10.15294/pandecta.v19i2.9593
Servicio de Rentas Internas. (2022a). Resolución No.
NAC-DGERCGC22-00000036: Instructivo para la aplicación de la
transacción en materia tributaria (Versión 1.0). https://www.sri.gob.ec/o/
sri-portlet-biblioteca-alfresco-internet/descargar?id=3d2dff1f-d71d-4a92
-a199-32c8d70f5555&nombre;=NAC-DGERCGC22-00000036.pdf
Servicio de Rentas Internas. (2022b). Resolución No.
NAC-DGERCGC22-00000053: Reforma al Instructivo para la aplicación
de la transacción en materia tributaria. https://www.sri.gob.ec/o/sri-portle
t-biblioteca-alfresco-internet/descargar?id=b1445afd-92f0-4222-97e9-4b
ee2c401109&nombre;=NAC-DGERCGC22-00000053.pdf
Conflicts of interest
The authors declare that they have no conflicts of interest.
Author contributions
Giannella Haz-Guevara and Teresa N. López-Macías:
Conceptualization, data curation, formal analysis,
investigation, methodology, supervision, validation,
visualization, drafting the original manuscript and writing,
review, and editing.
Statement on the use of AI
The authors acknowledge the use of generative AI and
AI-assisted technologies to improve the readability and clarity
of the article.
Data availability statement
The data supporting the findings of this study are available
from the corresponding author upon reasonable request. The
data are not publicly available because they contain
information collected from participants through the survey
conducted in Esmeraldas, Ecuador.
Disclaimer/Editor’s note
The statements, opinions, and data contained in all
publications are solely those of the individual authors and
contributors and not of Journal of Law and Epistemic Studies.
Journal of Law and Epistemic Studies and/or the editors
disclaim any responsibility for any injury to people or
property resulting from any ideas, methods, instructions, or
products mentioned in the content.
