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Dominican Republic: Update of “white list” countries, transfer pricing implications

Dominican Republic: Update of “white list” countries

The tax authority (DGII) of the Dominican Republic has updated its “white list” of jurisdictions—that is, countries and jurisdictions that are not considered as having preferential tax regimes or are not considered to be “tax havens.”


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The significance of the “white list” is that transactions with parties in countries not included on the “white list” may invoke application of the transfer pricing rules (regardless of whether the transaction involves a related party or not). Provisions under the transfer pricing rules of the Dominican Republic apply with respect to inter-company commercial or financing arrangements involving:

  • Related parties located abroad
  • Individuals and/or companies incorporated or located under “special tax regimes” that are considered to be tax haven jurisdictions—whether or not the subject transactions involve related parties
  • Related parties benefiting from the free trade zone regime

“White list” jurisdictions, previously “black listed”

The “white list” was previously updated in 2014. The most recently updated “white list” now includes 121 jurisdictions. The “black list” was last updated in 2013.

Countries or jurisdictions that previously had been “black listed” but have been moved to the “white list” after these jurisdictions implemented anti-abuse rules that follow the OECD’s base erosion and profit shifting (BEPS) guidelines are:  

  • Austria
  • Brunei
  • Luxembourg
  • Malta
  • Monaco
  • Montserrat
  • Netherlands
  • Niue
  • Philippines
  • San Marino
  • Uruguay 

“White list” jurisdictions not previously on “black list”

Countries or jurisdictions that are new to the “white list” but were not previously “black listed” are as follows:

  • Central African Republic
  • DR Congo
  • Gambia
  • Nepal
  • Seychelles
  • Somalia
  • Swaziland

Countries neither on “white list” nor “black list”

There are countries (listed below) that previously were on the “white list” but have been removed from that list. But they are not “black listed” either. These countries or jurisdictions, thus, are not on either the white list or the black list.

  • Armenia
  • Botswana
  • Cape Verde
  • Curacao
  • Fiji
  • Guadeloupe
  • Guam
  • Honduras
  • Iran
  • Palau
  • Israel
  • Kazakhstan
  • Micronesia
  • Mongolia
  • Namibia
  • Nicaragua
  • New Caledonia
  • Peru
  • Puerto Rico
  • Thailand
  • Taiwan
  • Tokelau
  • Tunisia
  • Turkey
  • U.S. Virgin Islands
  • Venezuela
  • Vietnam


Read a January 2017 report (English) [PDF 340 KB] or (Spanish) [PDF 351 KB] prepared by the KPMG member firm in the Dominican Republic

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