Insights · Ecuador

Dividends from Ecuador to foreign shareholders: the 10% rule, ownership reporting and the tax-haven test.

Since August 2025, Ecuador taxes dividends to non-residents at a flat 10% — if you disclose who owns the company. Here are the rates, the full cost of one profit, the reporting that sets your rate, and where a Paraguayan holding stands.

Reading time · 10 minTopic · Ecuador · TaxRules as of · October 2026Author · Alexander Baranov

The short version

  • Dividends to non-residents bear a flat 10% since August 2025; treaties can reduce it.
  • Undisclosed ownership: 28% corporate tax and 14% on dividends.
  • Profit share, corporate tax and dividend tax take about 42.6% of pre-tax profit; usually no ISD on top.
  • Ecuador dropped its preferential-regime list: you apply the two-of-three tax-haven test yourself.
  • No Ecuador–Paraguay treaty: a Paraguayan holding helps mainly for reinvestment.
01 · The rules since 2025

A flat 10% — and ownership you must disclose.

Ecuador rewrote its dividend tax in August 2025. Dividends paid to non-resident shareholders now bear a flat 10% on the gross amount, replacing an effective-rate formula that few could calculate. The rate goes up when the real owner is an Ecuadorian resident, when the chain runs through a tax haven, or when the company has not told the tax authority who owns it.

Add the 25% corporate tax and the employees’ 15% profit share, and the full cost of getting profit out of Ecuador is easier to model than before — provided the ownership reporting is in order. This guide covers the rates, the reporting, the tax-haven test and whether a Paraguayan holding makes sense.

Law and practice: Ley Orgánica de Transparencia Social (Registro Oficial, 3rd Suppl. 112, 28 August 2025), amending arts. 39.2 and 39.2.1 of the Internal Tax Regime Law (LRTI); Executive Decree 191 of 27 October 2025. A constitutional challenge filed in September 2025 was pending at the time of writing.

02 · Rates

Who pays what.

Who receives the dividendEcuadorian tax withheld
Non-resident company or individual10% of the gross dividend
Non-resident whose beneficial owner is an Ecuadorian resident12%
Chain through a tax haven, with an Ecuadorian beneficial owner14%
Portion of ownership not reported to the SRI14%
Shareholder in a treaty country (e.g. Chile, Canada, Spain)Treaty rate, typically 5–10%
Ecuadorian companyExempt

The tax is withheld in full when the shareholders resolve to distribute. Loans and advances to shareholders are treated as early dividends, so lending profit to the parent instead of paying it out does not avoid the tax.

Law and practice: LRTI art. 39.2. Sources differ on whether an Ecuadorian-resident beneficial owner always means 14% or only with a tax haven in the chain; we follow the reading of the major advisers (12%, or 14% with a haven).

03 · The numbers

One profit, all the way out.

US$1,000,000 profit before profit-sharing, all paid outAmountRunning total
Employees’ 15% profit shareUS$150,000US$850,000
Corporate income tax, 25%US$212,500US$637,500
Dividend tax to a non-resident owner, 10%US$63,750US$573,750
ISD on the transfer (no Ecuadorian owner in the chain)US$0US$573,750 to the owner
Total taken before the ownerUS$426,25042.6%
If ownership is not reported: 28% corporate tax and 14% on dividends—about 47.4%

For profit that stays in the company, Ecuador now charges a small advance tax on undistributed earnings — from 0% on the first US$100,000 to 2.5% at the top — which can be credited against later dividend tax if the profit is distributed or capitalised within two years.

Law and practice: LRTI art. 39.2.1. Illustrative figures; the profit share is deducted before corporate tax.

04 · Ownership reporting

REBEFICS: the report that sets your rate.

Every Ecuadorian company files an annual report of its full ownership chain, up to the individuals at the top, with the SRI. The report is known as REBEFICS. It is filed in February, by the ninth digit of the tax number, with changes reported by the 28th of the following month.

  • ✓

    Not filed on time

    Corporate tax rises from 25% to 28% on the whole profit.

  • ✓

    Incomplete

    28% on the unreported share — or on everything if half or more is unreported.

  • ✓

    Dividends

    14% on the part of the dividend linked to undisclosed owners.

  • ✓

    Penalties

    Separate fines for late or inaccurate reports.

Foreign groups trip on this more than on any rate: a holding company abroad that cannot produce its own shareholder register costs its Ecuadorian subsidiary three points of tax.

Law and practice: SRI Resolution NAC-DGERCGC24-00000033, in force 30 September 2024, arts. 15–16.

05 · The tax-haven test

Ecuador no longer gives you a list.

In August 2025 the SRI removed its list of preferential regimes and told taxpayers to apply the legal test themselves. A jurisdiction counts as a tax haven if it meets two of three conditions.

Test (two of three make a tax haven)Paraguayan holding with real substanceParaguayan shell
Effective income tax below 60% of Ecuador’s (under 15%)Met: IRE is 10%Met
Activity not carried out substantially thereNot metMet
No effective exchange of tax informationNot met: Paraguay applies the OECD multilateral conventionNot met
ResultNot a tax haven (1 of 3)Tax haven (2 of 3)

Paraguay is not on Ecuador’s list and, for a holding with real activity and management in Paraguay, does not meet the test. A Paraguayan shell would. Tax-haven status matters less for dividends to a foreign owner than for loans, royalties and the 28% rate, but it is a risk the taxpayer now carries alone.

Law and practice: LRTI, second unnumbered article after art. 4; SRI Resolution NAC-DGERCGC25-00000021 of 15 August 2025.

06 · A Paraguayan holding?

Usually no gain on dividends.

Ecuador has no tax treaty with Paraguay, so a Paraguayan holding pays the same 10% as any non-treaty shareholder. Paraguay then taxes the foreign dividend in the holding, with a credit for the Ecuadorian tax, and charges its own dividend tax (IDU) when the holding pays out: 8% to a Paraguayan resident, 15% to a foreign one.

  • ✓

    Foreign owner, profit paid out

    A Paraguayan layer adds cost. A holding in a treaty country such as Spain, Chile or Canada may cut the 10%.

  • ✓

    Owner living in Paraguay

    The Paraguayan layer costs 8% on distribution, not 15%; model it against holding directly.

  • ✓

    Profit reinvested in the region

    The holding can keep Ecuadorian dividends and fund other markets before any IDU.

  • ✓

    Substance

    Real management in Paraguay keeps the holding outside Ecuador’s tax-haven test.

For the treaty side of the region, see our Chile–Paraguay treaty analysis.

Questions

Straight answers.

What is the dividend tax in Ecuador for foreign shareholders?

10% of the gross dividend since the August 2025 reform, withheld when the distribution is resolved. Treaties can reduce it.

When does the rate rise to 14%?

When the ownership has not been reported to the SRI (on the undisclosed portion), or when the chain runs through a tax haven and the beneficial owner is an Ecuadorian resident.

Do dividends from Ecuador pay the 5% ISD?

No, if paid to a non-resident with no Ecuadorian residents in the ownership chain.

What is REBEFICS?

The SRI’s annual beneficial ownership and shareholding report. Late or incomplete filing raises corporate tax from 25% to 28%.

Is Paraguay a tax haven for Ecuador?

Not on the SRI’s former list, and a Paraguayan company with real substance does not meet Ecuador’s two-of-three test. A shell company could.

Does Ecuador have a tax treaty with Paraguay?

No. Ecuador’s treaties include Spain, Chile, Canada, Mexico, Brazil, Uruguay, the UK and the Andean Community, but not Paraguay.

Is there a tax on retained profits in Ecuador?

Yes, a small advance tax of 0–2.5% on undistributed profits, creditable if they are distributed or capitalised within two years.

Keep reading

Go deeper.

AB
Alexander BaranovFounder of the BCA network. Fifteen years in cross-border company formation, tax structuring and corporate law across 40+ jurisdictions — written from live client work, not theory. About the author →
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