On December 31, 2025 the Internal Revenue Service – SRI issued Resolution No. NAC-DGERCGC25-00000046, whereby Resolution No. NAC-DGERCGC25-00000046 is amended. NAC-DGERCGC22-00000046 and Resolution No. NAC-DGERCGC24-00000033, which regulate the obligation to submit information regarding beneficial owners, as well as the approval of REBEFICS. The following is a summary of its contents.

1.- At the end of paragraph b of Art. 4 of Resolution NAC-DGERCGC22-00000046, the following subsection shall be added:

    When private trusts, including those constituted by organizations of the popular and solidarity economy, are administered by institutions of the Ecuadorian State, the natural persons who hold the legal representation of these institutions, and the legal representatives of the constituents, will be considered as final beneficiaries.

    2.- After numeral 3 of Art 6 of Resolution NAC-DGERCGC24-00000033, the following subsection is added:

    4. When the obligor is an organization under the regime of the Organic Law of Popular and Solidarity Economy, it must report the information of its board members, administrators, persons with power of decision or control, attorneys-in-fact in general, and right holders, during the fiscal year reported, whose accumulated contributions exceed two basic fractions taxed at zero rate for the calculation of the income tax of individuals, in force for such fiscal year.

    This Resolution became effective as of its publication in the Official Gazette.

    Quito D.M. / Guayaquil, January 2026