Date: June 30, 2025 | Official Register Third Supplement No. 70; SRI Resolution No. NAC-DGERCGC25-00000015, dated June 27, 2025.

Subject: Application of the remission regime for 100% of interest, fines, surcharges, and costs on tax obligations.

• The following obligations are not eligible for remission:
  • Obligations collected but not administered by the SRI.
  • Obligations related to Income Tax for the 2024 fiscal year.
  • Tax obligations with no tax payable.
  • Monetary sanctions resulting from sanctioning procedures.
  • Amounts derived from audit processes related to undue tax refunds.

• Full payment of principal:
  • To benefit from the 100% remission of interest, fines, costs, and surcharges, the taxpayer must pay the full principal amount owed by December 31, 2025. If the taxpayer has a debit agreement in place, the SRI may request the financial institution to carry out a total or partial debit of the declared but unpaid principal, without prejudice to the taxpayer’s ability to use other payment methods.

• Treatment of prior and partial payments:
  • Payments made before June 25, 2025: will be treated in accordance with Article 47 of the Tax Code.
  • Payments made between June 26 and December 31, 2025: will be applied directly to the principal.
  • Payments made after December 31, 2025: will once again be subject to the regime established in Article 47 of the Tax Code.
• In cases where partial payments do not cover the full principal amount:
  • The SRI will update the outstanding balance based on payments made between June 26 and December 31, 2025.
  • The reduction will be applied proportionally to interest, fines, and surcharges due to the decrease in principal.
  • For obligations under payment agreements, the taxpayer must continue making payments according to the current plan, with the remission applied as appropriate.

• Obligations under enforcement: Obligations eligible for remission where the taxpayer pays the full principal:
  • The enforcement process will be closed
  • If there are ongoing legal proceedings, precautionary measures will be revoked and the case will be closed.

• Obligations included in mediation agreements may qualify for remission if the principal is paid. In this case:
  • The SRI will notify the Mediation Center of the full payment, so that the process may be closed due to lack of subject matter for settlement.
  • Upon notification, the process will be recorded and closed, and any suspended deadlines will be reactivated.

• Vehicle taxes: The SRI will automatically apply the remission to:
  • The annual motor vehicle ownership tax accrued up to the 2024 fiscal year.
  • The 1% tax on the sale of used vehicles, when the contract was legalized on or before December 31, 2024.

Remission will be applied once payment of the principal is verified by December 31, 2025.

Finally, payments that exceed the principal balance, made under this remission regime, will not be considered undue or excessive, and will not be subject to refund—except to the extent that they exceed the amount the taxpayer would have been required to pay outside the regime.

This Resolution will enter into force upon its publication in the Official Register.

If you require additional information, please contact us at the following email addresses:
cmedina@bustamantefabara.com and lutreras@bustamantefabara.com

Prepared by: Attorney Carolina Medina and Attorney Liliana Utreras.