Updates to the United States (US) Internal Revenue Service (IRS) website, dated 1 July 2025, include the Dominican Republic-United States Competent Authority Arrangement on the Exchange of Country-By-Country Reports (Arrangement).

Background

In October 2018, the Dominican Republic joined the Inclusive Framework of the Base Erosion and Pro?t Shifting (BEPS) Project of the Organisation for Economic Co-operation and Development (OECD), committing to implement the OECD minimum standards on BEPS. One of those standards is the implementation of BEPS Action 13 (local file, master file and country-by-country reporting (CbCR).

As part of the actions to implement the BEPS Action 13, the Dominican Republic's General Directorate of Internal Taxes (abbreviated DGII) issued General Norm 08-21 on CbCR (the Norm), in line with the provisions set forth in Decree 256-21 on transfer pricing, published in April 2021.

Obligated entities

The provisions set forth in the Norm reach taxpayers that are ultimate parent entities (UPEs) or obliged constituent entities of multinational groups (MNE Groups) that are tax residents in the Dominican Republic and have consolidated annual revenue equal to or greater than 38.8 billion Dominican pesos (DOP38.8b).

Important aspects of the Arrangement

The Arrangement would allow for the exchange of the CbCR between the Competent Authority in the United States and the Competent Authority in the Dominican Republic on an annual and automatic basis.

This Agreement would come into effect on the date of the last signature by the Competent Authorities. However, the Arrangement posted on the IRS webpage does not display the signatures of US or Dominican Republic signatories or provide the date when the agreement was signed, so affected entities must await an official statement from the Dominican Republic tax authorities to validate the activation of the Arrangement.