For a few months in 2023, the Dominican tax authority offered something rare: a legal path to wipe out or drastically shrink old tax debts. Law 51-23, enacted August 10, 2023, opened a special window, originally set to close on December 20, 2023, combining four tools that taxpayers seldom see together.

First, a statute-of-limitations declaration: the DGII could formally declare time-barred tax debts for periods up to and including 2015, covering income tax, corporate income tax, ITBIS (the Dominican VAT), the asset tax, real estate property tax (IPI), free-zone taxes and gaming taxes, provided the taxpayer met the law’s conditions and the DGII confirmed eligibility.

Second, payment facilities: graduated amnesties on surcharges and interest, with the discount depending on whether the debt arose from the taxpayer’s own returns, from DGII adjustments or from cases under appeal, and on whether payment was immediate or in installments.

Third, a reduced audit process: taxpayers under internal audit for the covered taxes could opt into a simplified determination based on an Effective Tax Rate set by the law, trading uncertainty for a predictable payable amount.

Fourth, an amnesty for government institutions on unpaid income tax and ITBIS withholdings through August 1, 2020.

The window has closed, but the law still matters for two reasons. Taxpayers who used it should keep the DGII resolutions and payment records permanently, they are the proof that old periods are settled if a future audit reaches back. And Law 51-23 is the template Dominican amnesties follow: businesses carrying disputed or aged tax debt should have their exposure quantified now, so they can move within days, not months, when the next facility opens, as the recent fiscal reform cycle suggests it may.

If your company has legacy Dominican tax debt, ongoing DGII adjustments or cases on appeal, our tax team can audit your exposure, pursue statute-of-limitations defenses and position you for any new payment facility.

Do you want more information about our services for Tax Amnesty Law in Dominican Republic? Contact Us.

ABOUT THE AUTHOR: Maria Arthur Rodger is a Partner leading the Private Client, Successions and Tax areas at Arthur & Castillo Advisers and Consultants in the Dominican Republic. She specializes in private client, successions, tax, real estate valuation and advisory (Master in Tax and Finance Studies from Georgetown University in Washington, D.C. & Universitat Pompeu Fabra in Barcelona) with more than 20 years of experience. She is also a Certified Public Accountant (CPA), Certified Valuator, Business Bankruptcy Expert and English and Spanish Interpreter.

Email: marthur@aclaw.com

Disclaimer: This publication is not intended to provide advice or suggest a guaranteed outcome as individual situations will differ and the situation may have changed since publication. For specific advice on the information provided and related topics, please contact the author.

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