Guayaquil Business Chambers Challenge SRI 60% Credit-Note Limit

Two Guayaquil business chambers are challenging an SRI rule that limits how companies can use credit notes to pay taxes.

The Guayaquil Chamber of Industries and the Guayaquil Chamber of Commerce filed a tax-contentious challenge against resolution NAC-DGERCGC26-00000015, dated March 31, 2026. The rule limits use of credit notes in tax declarations to 60% of the amount due from May 1, 2026.

Liquidity Issue

The remaining tax obligation, plus applicable fines and interest, must be paid through enabled payment methods in SRI's online system rather than through the available credit-note balance.

The chambers argue the restriction creates a negative liquidity impact on the productive sector by forcing taxpayers to use additional cash flow for obligations that could otherwise be compensated with valid credit notes. They also argue the measure limits companies' capacity to invest, grow, generate employment, and strengthen competitiveness.

SRI Rationale

SRI framed the measure as a way to avoid risk to the flow of tax collection that finances public spending. The legal dispute now centers on whether the limit exceeds what current rules allow.

What To Watch

Watch the procedural path of the tax-contentious action and any interim effect on companies that rely on credit notes for tax settlement. For corporate treasury teams, the immediate issue is cash planning: the rule shifts part of the tax-payment burden back to cash or bank transfer even where credit-note balances exist.