The Ecuador Internal Revenue Service (SRI) has published Resolution No. NAC-DGERCGC21-00000022 of 29 April 2021, which establishes new criteria for the qualification of an entity or individual as a large taxpayer with effect from 1 May 2021. The resolution provides that taxpayers considered as large taxpayers include those representing at least 50% of total taxes collected by SRI. For this purpose, SRI may use any of the following criteria:

• the volume and relevance of the taxpayer's transactions, the contribution to tax collection, and/or the behavior of the economic sector to which the taxpayer belongs, considering information analyzed for at least the last 5 fiscal years;
• the amount of the equity declared by the taxpayer or estimated by SRI; and
• other criteria established by SRI in relation to risk variables and/or tax and economic relevance.

When SRI determines a taxpayer is a large taxpayer based on the above, the taxpayer will be notified and placed under the supervision of the Directorate of Large Taxpayers. Such taxpayers will continue to be considered a large taxpayer until SRI decides/notifies otherwise. It is also provided that taxpayers that were notified as large taxpayers up to 30 April 2021 are also under the supervision of the Directorate of Large Taxpayers.