Policy & Regulation

SRI Cracks Down on ISD Tax Evasion in Foreign-Financed Imports

Ecuador Brief||Source: Boletín Contable

Enforcement Action

The Servicio de Rentas Internas (SRI) — Ecuador's tax authority — has launched an intensified enforcement campaign targeting evasion of the Impuesto a la Salida de Divisas (ISD), the 5% tax applied to capital outflows including payments for imported goods financed through foreign credit facilities, according to Boletín Contable and SRI communications.

ISD ParameterDetail
Tax rate5% of capital outflow value
Applicable transactionsForeign payments, import financing, dividend remittances, royalties
Key change (Jan 2025)ISD payments no longer creditable against income tax
Enforcement focusForeign-financed imports, split invoicing
Estimated evasion$150-$250M annually

Regulatory Context

The ISD was introduced in 2007 as a capital control measure to reduce dollarization-era outflows. It has undergone several modifications:

YearChangeImpact
2007ISD introduced at 0.5%Capital outflow monitoring
2008-2011Progressive increases to 5%Revenue maximization
2012-2024ISD payments creditable against income taxEffective rate reduced
January 2025Tax credit eliminatedFull 5% cost imposed
2026Enforcement intensificationEvasion schemes targeted

The elimination of the tax credit in January 2025 was a critical inflection point. Previously, importers paying ISD on foreign-financed purchases could offset those payments against their annual income tax liability, reducing the effective cost to near-zero for profitable companies. With the credit removed, the full 5% cost now applies, creating a strong incentive to evade.

Evasion Schemes Under Scrutiny

The SRI has identified several common evasion structures:

SchemeMechanismSRI Response
Split invoicingUnder-declaring import value to reduce ISD baseCross-referencing customs declarations with international trade databases
Offshore intermediariesRouting payments through third-country entities to obscure outflowBeneficial ownership disclosure requirements
Transfer pricing manipulationInflating costs of intercompany services to shift profits offshoreTransfer pricing audits expanded
Crypto-mediated transfersUsing cryptocurrency to move value without triggering ISDDigital asset monitoring regulations (proposed)
Loan restructuringConverting trade payables to intercompany loans with different tax treatmentSubstance-over-form analysis

Revenue Impact

The ISD is a significant revenue source for the Ecuadorian treasury:

ISD RevenueValue
2024 collection~$1.3 billion
2025 collection (est.)~$1.4 billion
Estimated evasion$150-$250 million
Share of total SRI revenue~7-8%
Share of non-oil fiscal revenue~10-12%

Closing the evasion gap would yield $150-$250 million in additional annual revenue — a material contribution to the fiscal consolidation targets under the IMF EFF program.

Import Sector Impact

For legitimate importers, the post-credit ISD represents a meaningful cost increase:

Import ScenarioPre-Jan 2025Post-Jan 2025
$1M import, foreign financed5% ISD, offset by income tax credit → effective cost ~0-1%5% ISD, no credit → effective cost 5%
Annual import cost impact ($10M importer)~$0-$100K~$500K
Margin compressionMinimal3-5 percentage points

Sectors most affected include:

  • Automotive — vehicle and parts imports from Asia, US, Europe
  • Technology/electronics — consumer and industrial equipment
  • Pharmaceuticals — active ingredients and finished products
  • Industrial machinery — capital equipment imports
  • Consumer goods — appliances, textiles, processed foods

Business Community Response

The Cámara de Comercio de Guayaquil and Fedexpor (export-import federation) have argued that the ISD — particularly without the tax credit — functions as an import tariff that raises costs for domestic businesses and consumers, distorts trade, and undermines Ecuador's competitiveness within the Andean Community.

The business community has advocated for:

  • Gradual ISD rate reduction (from 5% to 2-3%) over 3 years
  • Sector-specific exemptions for essential imports (medicines, agricultural inputs)
  • Restoration of the tax credit mechanism with appropriate controls
  • Alignment with WTO commitments (the ISD's classification as a non-tariff barrier is disputed)

What to Watch

  • SRI audit results — the enforcement campaign's first-round findings, expected mid-2026, will quantify discovered evasion
  • Constitutional challenges — several business groups have signaled potential legal challenges to the tax credit elimination
  • IMF program interaction — ISD revenue is factored into fiscal targets; any rate reduction would require compensatory measures
  • Import volume data — a sustained decline in formal imports could indicate trade diversion to informal channels or reduced economic activity
  • National Assembly proposals — legislation to modify ISD rates or restore credits; any bill advancing through committee would be market-relevant
  • Regional competitiveness — Colombia and Peru do not impose equivalent capital outflow taxes; comparative cost analysis may influence policy review

Source: Boletín Contable

Source

Boletín Contable — “SRI pago impuesto salida de divisas importaciones

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ISDSRItax enforcementcapital outflow taximportsevasion
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