On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. The general rule is aligned with the model legislation included in the OECD’s base erosion and profit shifting (BEPS) 2015 final report under Action 13 on transfer pricing documentation and country-by-country reporting. Under this general rule, the materiality threshold and assumptions for the filing of the CbC Report is established. This includes:

• In accordance with the general rule, the ultimate parent entity of a multinational group that is resident for tax purposes in the Dominican Republic and has consolidated revenue equal to or greater than DOP 38.8 billion shall file a CbC report starting with fiscal year 2022.
• The CbC report is due no later than 12 months after the last day of the fiscal year of the multinational group.
• This rule also describes the tax administration shall use the report for purposes of assessing high-level transfer pricing risks and other base erosion and profit shifting related risks and where appropriate for economic and statistical analysis.
• All group members resident in the Dominican Republic are required to submit a notice by the last day of the reporting year that includes information on whether the company is the ultimate parent company, or, if none, information on identity and country of residence of the reporting unit.
• A Member Entity that is a resident for tax purposes in the Dominican Republic but not the Ultimate Parent Company of a Multinational Group need to submit the CbC report with the same due time if any of the following conditions are satisfied:

a) The Ultimate Parent Company of the MNE Group is not required to submit a Country Report by Country in the jurisdiction of your tax residence;

b) the ultimate parent’s jurisdiction of residence has an in-force international agreement for exchange of information to which the Dominican Republic is a party, but does not have a qualifying competent authority agreement for the exchange of CbC reports in force with the Dominican Republic for the reporting fiscal year; or

c) there has been a systemic failure for exchange by the ultimate parent’s jurisdiction of residence and this has been notified by the DGII to the constituent entity.