On 14 June 2016, Ecuador published Resolution NAC-DGERCGC16-00000204 in the Official Gazette, which introduces a cap on the automatic application of tax treaty benefits for payments to non-residents. With immediate effect, total payments in excess of USD 223,400 per non-resident are not eligible for automatic treaty benefits, but instead subject to domestic withholding rates. However, the non-resident may still apply for a refund of the excess tax withheld, if any.
The whole of 2016 is cons…