On 4 January 2016, Ecuador published Resolution No. DGERCGC15-00003185 in the Official Gazette. The resolution sets out the conditions for a non-resident in a tax haven or low-tax jurisdiction to be deemed not a resident in such a jurisdiction for tax purposes if holding capital rights in a company resident in Ecuador or with a permanent establishment (PE) in Ecuador. The conditions include:
- The non-resident has issued securities listed on a stock exchange not located in a tax haven or low-t…