Key takeaways
- Most reviews begin with a discrepancy in reported data, not with suspicion.
- Deadlines to respond are short and strict — silence is treated as acceptance.
- The strongest defence is documentation that already exists.
- An assessment can be challenged administratively and, ultimately, before the courts.
- Most disputes are resolved on evidence long before litigation.
A notice from the DGII is alarming to receive and usually mundane in origin. Dominican tax administration is heavily data-driven: the monthly 606 and 607 formats cross-reference your declared operations against those reported by your suppliers and customers, and the system surfaces mismatches automatically. Most reviews start there rather than with any belief that something is wrong.
How reviews usually begin
Three patterns account for most of what we see. A cross-reference mismatch, where a counterparty reported a transaction you did not, or vice versa. A ratio that looks unusual for the sector — margins, credits carried forward, or withholding that does not track payroll. And omission: a return assigned on the RNC was not filed, including a required nil filing during inactivity until the DGII record is formally changed.
The important point is that each of these has a documentary answer. A mismatch caused by a supplier reporting a sale to the wrong RNC is resolved by showing what actually happened, not by arguing about it.
The process, in outline
A review typically opens with a requirement for information: specific periods, specific documents, a defined deadline. What you produce at this stage shapes everything that follows. If the response satisfies the reviewer, the matter closes. If it does not, the DGII may issue a determination adjusting the tax declared, with the surcharges and interest that accompany it.
An adverse determination is not the end. It can be challenged through the administrative channels available and, where that does not resolve it, before the courts. Each stage has its own deadline, and the deadlines are strict — a well-founded position lost to a missed date is the most avoidable outcome in tax practice.
What actually decides the outcome
Documentation prepared before the review, not arguments prepared during it. In practice that means valid fiscal receipts supporting input credits, contracts that match the invoices issued under them, evidence that services charged were actually delivered, and — for groups charging management fees or royalties to a Dominican entity — the transfer pricing analysis performed around the time of the transaction rather than reconstructed afterwards.
The pattern in weak files is consistent: a real commercial arrangement with no contemporaneous paper trail. The transaction was genuine, everyone remembers it, and nothing evidences it.
How to respond
Four things matter. Answer within the deadline, even if the answer is partial, because silence is treated as acceptance. Answer precisely what was asked — volunteering unrelated material broadens the review. Be consistent with what you have already filed, since contradicting your own returns creates a second problem. And assess the position honestly: where an adjustment is correct, resolving it early limits surcharges, while defending an indefensible position multiplies them.
Prevention is most of the work
The companies that never receive a determination are not lucky; they are the ones whose monthly filings reconcile, whose supplier invoices carry proper receipts, and whose intercompany charges are documented. That is the discipline set out in our compliance calendar and our tax guide for foreign companies.
If a notice has already arrived, the priority is the deadline in it. Our tax desk handles reviews from the first requirement through to determination and challenge.
Frequently asked questions
Why did the DGII open a review of my company?
Most reviews begin with data rather than suspicion — typically a cross-reference mismatch between your 606 and 607 filings and what a counterparty reported, an unusual ratio for your sector, or periods where nothing was filed.
What happens if I miss the response deadline?
Deadlines are strict and silence is treated as acceptance, so a well-founded position can be lost simply by not answering in time. Answering partially within the deadline is better than answering fully after it.
Can I challenge a tax determination?
Yes. An adverse determination can be challenged through the available administrative channels and, where that does not resolve it, before the courts. Each stage carries its own strict deadline.
What is the strongest defence in an audit?
Documentation that already existed — valid fiscal receipts, contracts matching the invoices issued under them, evidence that services charged were delivered, and transfer pricing analysis prepared around the time of the transaction.