2026 Amendments to Ecuador’s Tax Code: Key Changes for Taxpayers and Businesses
Does your company have pending tax claims, refund requests, or tax enforcement proceedings? Amendments to Ecuador’s Tax Code may affect filing deadlines and the options available to challenge tax assessments and administrative decisions.
The Organic Law Amending the Tax Code was published in Official Gazette No. 392, Ninth Supplement, on October 19, 2026, and entered into force upon publication, subject to the specific transitional and temporal rules established by law.
The amendments address the following areas:
Tax Administration Powers
Regulatory hierarchy, legality, and notifications.
Taxpayer Rights
Prospective application of changes in administrative interpretations.
Tax Appeals and Refunds
Administrative claims, review appeals, and tax refunds.
Tax Enforcement Proceedings
Service of payment orders and enforcement defenses.
Penalties
New ranges of administrative fines.
Foreign Assets
Penalties for failing to report foreign assets in the required asset declaration.
Below, we explain each change and what businesses should review.
Legality, Administrative Interpretations, and Notifications
The amendments strengthen the rules governing the Tax Administration's regulatory authority and the application of its administrative interpretations.
Regulatory Hierarchy
Regulations, resolutions, and other administrative instruments must comply with applicable laws and the established hierarchy of legal authority.
Manuals, guidelines, technical specifications, and internal administrative interpretations may not create, modify, or extinguish tax obligations or alter the meaning of statutory provisions.
Changes in Administrative Interpretations
Changes in interpretation that impose a greater tax burden may not be applied retroactively.
Changes in administrative interpretations intended to have general application must be established through a duly published legal instrument.
Notifications
New rules govern notifications, with particular attention to electronic communications and the channels expressly designated by taxpayers.
Key action: Keep registered addresses and email accounts up to date with the Tax Administration.
Key Deadlines Under the Amendments
Five important deadlines businesses should monitor when dealing with administrative claims, review appeals, and tax enforcement proceedings.
AdministrativeClaims
120 business days
As a general rule, the maximum period for the Tax Administration to issue and serve a decision, starting on the business day following the filing of the claim.
Administrative Review Appeals
10 days
To clarify or supplement the filing, where applicable.
180 days
For the administrative authority to issue a reasoned decision.
Tax Enforcement Proceedings
20 days
To file a complaint challenging the enforcement proceeding, starting on the day following service of the payment order.
Transitional Provision
180 business days
To resolve pending administrative review appeals, starting on the day following publication of the law.
For administrative claims, the amendments provide for circumstances in which the deadline may be suspended, as well as specific rules for certain proceedings, including customs-related claims.
Tax Refunds, Administrative Review Appeals, and Enforcement Proceedings
The amendments introduce changes to the procedures governing tax refunds, administrative review appeals, and tax enforcement proceedings.
Tax Refunds
New rules govern refund applications and the available remedies when a refund is denied in whole or in part, or when the taxpayer considers the amount approved to be incorrect.
The amendments also address the refund of amounts owed to taxpayers when discrepancies are identified in decisions resolving administrative claims or appeals, subject to the applicable statutory time limits.
Administrative Review Appeals
The grounds for filing, admissibility requirements, and circumstances in which an appeal may be rejected are revised.
The amendments expressly regulate the consequences of the administrative authority's failure to issue a decision within the statutory deadline.
Tax Enforcement Proceedings
The rules governing service of payment orders and the filing of objections to tax enforcement proceedings are revised.
Taxpayers have 20 days to file a complaint challenging the enforcement proceeding, subject to the statutory requirements.
New Ranges of Administrative Fines
The amendments establish new fine ranges for tax-related infractions classified as contraventions and regulatory violations.
Contraventions
Contraventions may be subject to fines ranging from 6% of one Unified Basic Salary (SBU) to three Unified Basic Salaries.
Regulatory Violations
Regulatory violations are subject to fines ranging from 6% of one Unified Basic Salary to two Unified Basic Salaries, without prejudice to other applicable penalties.
SBU: Ecuador's Unified Basic Salary (Salario Básico Unificado).
Foreign Assets: New Penalty
The amendments introduce a specific penalty for failing to report foreign assets in the required asset declaration.
Who Is Subject to This Penalty?
Taxpayers required to file an asset declaration who fail to report all or part of their assets located outside Ecuador.
Fine
Calculated based on the total value of the unreported assets.
Maximum Penalty
Subject to a statutory cap expressed in Unified Basic Salaries.
Reduction
The fine may be reduced by 50% if the taxpayer files the declaration late but before receiving formal notice of the violation from the Tax Administration, subject to the applicable statutory limit.
What Should Businesses Review Now?
Companies should review ongoing proceedings, appeal deadlines, pending refund applications, and formal tax compliance obligations to identify potential legal implications and available defense strategies in a timely manner.
Review Ongoing Proceedings
Identify pending administrative claims, review appeals, refund applications, and tax enforcement proceedings whose deadlines may be affected by the amendments.
Strengthen Notification Controls
Verify the registered address and email accounts maintained with the Tax Administration..
Assess Pending Tax Refunds
Review payment dates, application filing dates, and notification dates for administrative decisions to determine which legal remedies remain available.
Reassess Tax Dispute Strategies
Evaluate available grounds and procedural options for challenging tax assessments and administrative decisions, taking into account the amended rules.
Verify Asset Declarations
Confirm that all foreign assets have been reported accurately and within the applicable deadlines.
Challenge Administrative Requirements That Lack Sufficient Legal Basis
Assess whether administrative requirements are supported by applicable legislation and duly published regulations.
How Can We Assist?
The Meythaler & Zambrano Abogados team advises companies and taxpayers on:
Analyzing tax legislation and regulatory amendments.
Assessing their legal implications and potential impact on business operations.
Developing tax compliance and dispute strategies before the Tax Administration.
Head of the Tax Department
Quito: PBX (593-2) 223-2720
Guayaquil: (593-4) 390-1953
