On October 16, 2025, Legislative Decree No. 427 was published in the Official Gazette, enacting the Special and Transitory Law Granting Facilities for the Voluntary Compliance of Tax, Customs, Traffic, and Other Penalties (the “Tax Amnesty Law” or the “Law”). This regulation was approved by the Legislative Assembly to promote the voluntary regularization of debts owed to the State, without the application of surcharges, interest, or penalties.

Among the decree’s most relevant aspects are the following:

1. Main objective: Temporary and special amnesty regime

The Law establishes a temporary and special amnesty regime designed to facilitate the payment of outstanding obligations in various areas. These include domestic taxes administered by the General Directorate of Internal Taxes (DGII), customs obligations managed by the General Directorate of Customs (DGA), and traffic fines related to the Land Transportation, Traffic, and Road Safety Law.

Through this measure, the Government seeks to encourage voluntary compliance, stimulate economic activity, and recover fiscal revenues to strengthen public finances.

2. Main benefits for taxpayers

Taxpayers who take advantage of this regime may benefit from the total exemption of interest, surcharges, and fines associated with their pending obligations. Additionally, they will be granted payment facilities, either through a single payment or through deferred or installment plans.

The benefits also extend to taxpayers involved in administrative or judicial collection proceedings, provided that there is no final, liquid, and enforceable judgment.

3. Duration and scope of the amnesty regime

The Law establishes a period of 60 calendar days, counted from its effective date, during which taxpayers may regularize pending tax, customs, and other debts.

During this period, taxpayers with obligations administered by the Ministry of Finance may apply for the regime, including those with ongoing proceedings before the DGII, DGA, Tax and Customs Appeals Tribunal, the Contentious-Administrative Jurisdiction, or the Office of the Attorney General of the Republic.

The Law also covers individuals with traffic fines or other administrative penalties imposed by public institutions (excluding municipalities), as well as taxpayers who failed to make timely Income Tax payments or whose declarations or registered goods correspond to periods up to July 31, 2025.

Payments or declarations made within this period will be eligible for exoneration of interest, surcharges, and fines under the terms established by the Law.

The Tax Amnesty Law represents a unique and temporary opportunity for both individuals and legal entities to regularize their fiscal situation and contribute to national economic stability. Its approach promotes cooperation between taxpayers and the State, prioritizing voluntary compliance and encouraging economic activity.

For more information, please contact our team at [email protected]