Countries › Dominican Republic › Guide › 6. Taxes › Tax audits and disputes in the Dominican Republic: three year limit, 20 day appeal, tribunal and prompt payment

Tax audits and disputes in the Dominican Republic: three year limit, 20 day appeal, tribunal and prompt payment

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Last verified: 2026-10-30 · Status: Changing

DGII has three years to assess, extended by suspensions, and since Ley 30-26 unpaid declared debts also suspend the period. Taxpayers have 20 days for reconsideration and then 30 days to go to the administrative tax court, named Tribunal Contencioso Tributario y Administrativo in the code. Prompt payment discounts of 30% to 90% of surcharges reward settling, and a plan needs 15% down.

USD figures use the Banco Central de la República Dominicana reference selling rate of RD$60.8594 per US dollar for 28 October 2026, the latest row in its published rate file on the verification date, rounded to the cent.

Key facts

Limitation period	3 yearsLey 11-92 art. 21, as of 2026-10-30 · in force
Added suspension	Up to 2 yearsLey 11-92 art. 24, as of 2026-10-30 · in force
Reconsideration	20 daysLey 11-92 art. 57, as of 2026-10-30 · in force
Court appeal	30 daysLey 11-92 art. 144, as of 2026-10-30 · in force

The rule

1. DGII's actions to require returns, challenge them, collect or assess prescribe in three years, and so do taxpayer refund claims. The period runs from the filing and payment deadline.Ley 11-92, Código Tributario, art. 21 and art. 22, 1992-05-16 official text · verified 2026-10-30

2. A filing, acknowledgment or collection act interrupts the period and it starts again. It is suspended during appeals, and up to two years for not filing, false filing, the start of an audit or, since Ley 30-26, failure to pay.Ley 11-92, Código Tributario, as amended by Ley 30-26, art. 23 and art. 24, 2026-06-18 official text · verified 2026-10-30 · changed: Ley 30-26 art. 4 added failure to pay as a suspension ground.

3. DGII can assess by itself if no return was filed, if the return lacks credibility or books are missing. Withheld taxes not declared can be demanded at once.Ley 11-92, Código Tributario, art. 66 and art. 67, 1992-05-16 official text · verified 2026-10-30

4. Reconsideration is filed in writing within 20 days of receiving the decision, and suspends payment of tax and surcharges until decided, while interest runs. DGII may give up to 30 days to expand it.Ley 11-92, Código Tributario, art. 57, 1992-05-16 official text · verified 2026-10-30

5. Reconsideration must be exhausted first, and DGII has 90 days to decide, after which the taxpayer can go to the court. The court action is due in 30 days from notice or from the end of the period. A non resident needs a known representative.Ley 11-92, Código Tributario, art. 139, art. 144 and art. 145, 2007-07-17 official text · verified 2026-10-30

6. Tax court decisions can go to the Supreme Court on cassation.Ley 11-92, Código Tributario, art. 176, 1992-05-16 official text · verified 2026-10-30

7. Determined debts are due within 30 business days of notice or of the decision on reconsideration. A taxpayer can deposit the amount in dispute and appeal to avoid conservatory measures, with no admission.Ley 11-92, Código Tributario, as amended by Ley 30-26, art. 16 paragraphs II and IV, 2026-06-18 official text · verified 2026-10-30 · changed: Ley 30-26 art. 2.

8. Payment plans need at least 15% down, a real or personal guarantee, interest on the balance and monthly payments, up to 12 months, or 24 for debts covering periods above 12 months. Missing three payments ends the plan. Only one plan can be in force.
Cost to do it: 15% down, plus interest and any guarantee costs.Ley 11-92, Código Tributario, as amended by Ley 30-26, art. 17-1, 2026-06-18 official text · verified 2026-10-30 · changed: New article, added by Ley 30-26 art. 3.

9. Prompt payment discounts on surcharges: 90% for a voluntary correction before any request; 70% if, once an audit starts, the taxpayer accepts the potential debt; 50% if a final assessment is paid in 30 days; 30% if an appeal is withdrawn and payment made. Fraud cases get none.Ley 11-92, Código Tributario, as amended by Ley 30-26, art. 252 paragraph II, 2026-06-18 official text · verified 2026-10-30 · changed: Replaced the earlier 60% and 70% payment scheme.

10. Surcharges are suspended from the start of an audit until the payment deadline in the final notice.Ley 11-92, Código Tributario, as amended by Ley 30-26, art. 252 paragraph I, 2026-06-18 official text · verified 2026-10-30

11. DRAFT, NOT IN FORCE. The draft says a deposit suspends surcharges and interest, DGII must accept it, and the 70% discount must be requested within 20 business days of the notice of potential debt.Draft regulation of Ley 30-26, art. 2 and art. 5, 2026-10-30 official text · verified 2026-10-30

Stage	Time	Effect
Audit and notice	Within limitation period	Surcharges suspended
Reconsideration at DGII	20 days	Payment suspended, interest runs
DGII decision	90 days	Opens the court
Tribunal action	30 days	Per art. 144
Cassation	Per current rules	Supreme Court

Dispute path

Trigger	Discount	Surcharge paid
Voluntary correction	90%	RD$100,000
Accept during audit	70%	RD$300,000
Pay final assessment in 30 days	50%	RD$500,000
Withdraw appeal and pay	30%	RD$700,000

Effect of discounts on a RD$1,000,000 surcharge

Worked example

An assessment shows RD$5,000,000 (about US$82,156.58) of tax. A payment plan needs RD$750,000 (about US$12,323.49) down, and the balance of RD$4,250,000 (about US$69,833.09) over up to 12 months with interest.

Step by step

Register a notification channel and watch it.
On a notice, count 20 days at once.
Compare discount to the odds of winning.
File with reasons and evidence.
If DGII does not answer in 90 days, weigh going to court.

Common traps

Time limits are short and the code counts the 20 days from receipt.
The art. 176 deadline in the compiled code should be checked against later cassation legislation, so this page does not state it.
The pre payment rule in art. 143 is noted in the code as declared unconstitutional.
Cases with fraud lose the discounts.

Sources

Related: Dominican Republic country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

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