DT6403 - Double Taxation Relief Manual: Guidance by country: Ecuador

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Ecuador is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject

Comments

Article

Portfolio dividends

10% (Note 1)

10

Dividends on direct investments

5% (Note 1)

10

Conditions for lower rate on dividends on direct investments

A company which controls, directly or indirectly, at least 25% of the capital of the company paying the dividends

10

Property income dividends

15% (Note 1)

10

Interest

10% (Note 2)

11

Royalties

10%

12

Government pensions

Taxable only in Ecuador unless the individual is a resident and national of the UK.

19

Other pensions

Taxable only in the UK.

18

Arbitration

No

N/A

Note 1: Other than where the beneficial owner of the dividend is a pension scheme in which case the dividend is exempt from tax.

Note 2: Interest is taxable only in the UK where the beneficial owner of the interest is:

  • the UK government, a political subdivision or local authority of the UK or any agency or other entity wholly-owned by any of these authorities
  • the Bank of England
  • a UK resident financial institution
  • a UK resident pension scheme