The first thing to know is how many days are left. And there are two deadlines that are often confused.
The first is for the written defence: twenty working days, counted from the day the company collects the summons detail, to answer the audit findings in writing with the evidence that supports each position. The authority may grant an extension of up to ten working days, but it must be requested. It is set by General Norm núm. 07-14, under which the facts are deemed admitted if no defence is filed.
The second is for the request for reconsideration: thirty working days from service of the assessment. It is the deadline in Article 53 of Law núm. 107-13 on the rights of individuals in their dealings with the administration, and it is the position the Supreme Court of Justice has upheld for reconsideration and the stages that follow, over the twenty days still stated in Article 57 of the Tax Code.
The consequence is concrete and worth stating plainly: the twenty days are for defending the file before the auditor, not for appealing. And the written defence is where the case is won or lost: what was not proven there is rarely proven at reconsideration. If you have been served, the first question is not what a defense costs — it is what date it was handed to you and which stage you are in.
The deadlines, with the provision that sets each one
None of these run from the day you found out. They run from service or collection of the notice, in working days.
| Step | Deadline | Provision |
|---|---|---|
| Written defence to the audit | 20 working days from collection of the summons detail; extension of up to 10 working days, on request | General Norm núm. 07-14 |
| Request for reconsideration | 30 working days from service of the assessment | Art. 53, Law núm. 107-13; Supreme Court of Justice case law |
| Extension of the filing | Up to 30 further days, if granted | Art. 57, Tax Code (Law núm. 11-92) |
| Decision by the authority | 90 days. Once elapsed, the judicial route opens | Art. 139, as amended by Art. 3 of Law núm. 173-07 |
| Tax litigation appeal | 30 working days from service | Art. 144, as amended by Law núm. 13-07 |
| Against action taken without legal basis | 10 days | Art. 144, as amended by Law núm. 13-07 |
| Appeal to the Supreme Court | Two months from service of the judgment | Art. 176, Tax Code |
What changes once the request is filed
Filing the request for reconsideration suspends the obligation to pay until a decision is issued, under Paragraph I of Article 57, added by Law núm. 227-06. This is not a procedural footnote: it is what keeps the assessment from becoming enforceable while it is being contested.
Exhausting the administrative route is mandatory before going to the Superior Administrative Court, under Article 3 of Law núm. 173-07. A file that skips that step does not reach the court.
How the file is built
A notice of adjustment is not answered with a letter. It is answered with the file.
- We read exactly what is being asserted against you and for which periods. Many notices cover less ground than the alarm they cause suggests.
- We locate the supporting documentation for each item questioned. This is where the time is won or lost.
- We prepare the written response, with the documents that support each position and the provision that backs it.
- If that does not resolve it, we file the request for reconsideration. And if the matter advances to a forum requiring accredited representation, the firm takes it on: you have one point of contact and one party accountable, at every stage.
Why we reach the supporting documents sooner
Some firms file well and do not litigate. Some lawyers litigate and never saw the entry being made. The client is left in between, explaining his own books to the person who is about to defend them.
When monthly compliance is handled by the same team that will answer for it, every figure has its support identified from the moment it is recorded. That is why a written response takes days to prepare rather than weeks, and it is also why we take on files we did not keep: in that case the first thing we do is reconstruct the support, and tell you which items have it and which do not.
What we do not do
We do not forecast the outcome. We cannot, and neither can anyone who promises you one. What we can tell you, with the file in front of us, is which documents support your position and which do not — and if our reading is that there is no defense, we will tell you in those words.
What we need in order to give you an answer
Three things, and that is enough for us to tell you the same day whether there is a case and how much time is left:
- The assessment as served, in full, and the date it was handed to you.
- The periods and the taxes it covers.
- What was filed for those periods, even if you did not prepare it.
Deadlines verified against the Dominican Tax Code and its amendments, Law núm. 107-13 and General Norm núm. 07-14, as at September 2026. · Write to us · See our tax advisory practice