Report And Recommendations On The Main Amendments Introduced By Law No. 30-26 On Pro-economic Growth Measures, Tax Simplification, And Mitigation Of The International Crisis

I. INTRODUCTION

Law No. 30-26 on pro-economic growth measures, tax simplification, and mitigation of the international crisis, enacted on June 18, 2026, constitutes the broadest tax reform in recent years in the Dominican Republic. It structurally amends the Tax Code (Law No. 11-92) and numerous sectoral laws, with a stated dual purpose: simplifying compliance and increasing long-term tax pressure.

For taxpayers, the net effect is mixed. Alongside procedural improvements of undeniable value—such as the elimination of prior payment as a condition for filing an appeal and a discount regime for prompt payment—the law significantly expands the scope of taxation, especially on cross-border transactions and large taxpayers. This report sets out, in an organized manner, what the law provides, when each measure enters into force, a comparative table of the prior regime and the changes introduced, and concrete action recommendations. References in parentheses correspond to the articles of Law No. 30-26 and, where indicated, to the articles of the Tax Code (TC) that it amends.

II. WHAT DOES LAW NO. 30-26 PROVIDE?

The reform may be summarized in six major areas, described below, with comparative details and the implementation calendar set out in the following sections.

Income Tax. For individuals, the progressive scale is reorganized beginning in fiscal year 2027, increasing the exemption threshold to RD$480,000 and creating a new 27% bracket for income above RD$4,800,000, with annual inflation adjustment (Art. 10, TC 296). For legal entities, the general 27% rate is maintained (Art. 15, TC 297), but a temporary 30% surcharge is introduced for taxpayers with income equal to or greater than RD$1 billion during fiscal years 2026 to 2028. Advance payments are reorganized beginning in 2027 (Art. 23, TC 314), accelerated depreciation of industrial machinery is allowed (Art. 24), real estate capital gains of individuals are taxed at 10% as a single payment (Art. 14, TC 296-1), and crypto assets are expressly recognized as capital assets (Art. 19, TC 289).

Worldwide income and payments abroad. Foreign-source income from investments, financial gains, and technical assistance is taxed (Art. 12, TC 269), with an extremely broad definition of “technical assistance” that includes software, IT, cloud services, AI, cybersecurity, and nearly any professional service. Technical assistance “used in the country” becomes Dominican-source income even when provided from abroad (Art. 18, TC 272). In parallel, a 15% withholding is established on royalties (Art. 21, TC 305-1) and on software licenses, online advertising, and data storage (Art. 22, TC 305-2), with the general withholding on payments abroad set at the rate under Art. 297 (Art. 20, TC 305).

Tax procedure and payment facilities. The “solve et repete” requirement is eliminated: taxpayers may consign the amount and appeal without previously paying the debt (Art. 2, TC 16). Payment agreements are regulated—initial payment of 15%, guarantees, and installments of up to 12 or 24 months— (Art. 3, TC 17-1); compensatory interest is tied to the market rate (BCRD plus 30 basis points) (Art. 6, TC 27); the late-payment surcharge remains at 3% per month with a 100% cap and is suspended during audits (Art. 7, TC 252); and prompt-payment discounts of 90%, 70%, 50%, and 30% of surcharges are introduced.

Tax amnesty. An amnesty is granted only until December 31, 2026 (Art. 8) to regularize debts under litigation, final debts of delinquent taxpayers, and omitted tax returns, by paying the tax due plus up to one year of interest or surcharges, with the possibility of installment payment over up to 12 months.

ITBIS. An ITBIS collection regime is created for unregistered importers, administered by the DGA (Art. 34, TC 354-1); the Simplified Tax Regime is reorganized and extended to ITBIS obligations (Arts. 25 and 35); and exemptions are expanded—milk, bottled natural water, pasta, and asphalt for paving, as well as ambulances, fire trucks, and garbage collection trucks— (Arts. 36 to 39).

Excise Taxes and other taxes. For alcohol, tobacco, and vaping devices, the ad valorem base is calculated on the “final consumer price” (Art. 41, TC 367); a 55% excise tax on vaping and an additional 20% on tobacco are introduced (Arts. 42-43); the excise tax on life insurance is phased out (11% in 2027, 6% in 2028, and exemption beginning in 2029) (Art. 48); the LPG Contribution of US$174.50 per metric ton is created (Art. 49), and the collection of RD$2.00 per gallon on fuels is transferred to the DGA (Art. 50). The 2 per thousand tax on checks and transfers is maintained (Art. 40), the 1% tax on company incorporation is repealed and the tax on real estate transactions is reduced (Arts. 58-59), inheritance and gift tax exemptions are increased (Arts. 55-57), and the departure tax rises to US$30 (Art. 60).

III. EFFECTIVE DATE CALENDAR

The law is effective as of its enactment and publication (Art. 62), but many provisions have their own application dates, making it advisable to map the calendar carefully.

Immediately applicable: payment agreements, prompt-payment discounts, the 10% real estate capital gain tax for individuals, the exemption for persons over 65, elimination of prior payment as a condition for appeal, the US$30 departure tax, and the tax amnesty (in effect until December 31, 2026).

As of July 1, 2026: the 3% late-payment surcharge, the new withholding rates under Art. 309, the 15% withholdings on payments abroad (royalties, software, online advertising, and data storage), and taxes on casinos, lottery betting shops, sports betting shops, and slot machines; and, as of July 3, 2026, the 2 per thousand tax on checks and transfers.

By fiscal year: in 2026 they apply the corporate rate of 27%, the transitory surcharge of 30% for large taxpayers and the expanded deduction for educational expenses; in January 2027, the compensatory interest rate is revised; in 2027 the new scale of the ISR for individuals, the new advance payment regime, the beginning of the dismantling of the ISC on life insurance, the repeal of 1% on the incorporation of companies and the reduction to 1% of the tax on real estate transactions; in 2028 the 30% surcharge ends, the ISC on life insurance drops to 6% and the tax on real estate transactions is eliminated; and in 2029 large taxpayers return to the rate of 27% and life insurance is exempt from the ISC.

It should be noted that much of the operational implementation—payment agreements, the Simplified Tax Regime, ITBIS collection, excise tax control mechanisms, and refunds—remains subject to DGII general rules and Executive Branch regulations yet to be issued, so this analysis should be reviewed as regulations are published.

IV. COMPARATIVE TABLE: PRIOR REGIME AND CHANGES

The following table summarizes, for the highest-impact measures, the prior regime, the change introduced by the reform, and its effective date.

V. EXECUTIVE SUMMARY AND RECOMMENDATIONS

Law No. 30-26 combines, in a single instrument, relief measures and procedural improvements with a substantial increase in tax burden and control. The greatest impact falls on large taxpayers—because of the temporary 30% surcharge—and on cross-border structures, due to the expansion of worldwide income, the very broad definition of technical assistance, and the new withholdings on payments abroad. At the same time, the amnesty window offers a limited opportunity to regularize contingencies under favorable conditions before year-end.

Accordingly, we recommend that companies: (i) quantify exposure to the 30% surcharge and project its effect for 2026-2028; (ii) map all payments abroad by category and recalculate withholdings under Arts. 305, 305-1, and 305-2, reviewing the interaction with treaties to avoid double taxation; (iii) audit intragroup service agreements in light of the broad definition of technical assistance and the new source rule; (iv) evaluate, before December 31, 2026, whether it is advisable to apply for the amnesty; (v) verify RNC registrations to avoid ITBIS collection and review eligibility for the Simplified Tax Regime; (vi) identify capital investments that qualify for accelerated depreciation; and (vii) monitor—and, where appropriate, participate in—the consultation process for pending regulations, which will define key operational aspects.