DGII tax regulations challenged in unconstitutionality lawsuit

Journalist José Pegueroy and tax attorney Pablita Cabrera Martínez have filed a direct action of unconstitutionality before the Constitutional Court against regulations issued by the General Directorate of Internal Taxes (DGII).

The legal challenge targets Article 24 of General Rule No. 04-2021 regarding the National Taxpayer Registry (RNC), as modified by General Rule No. 04-2023. Specifically, the plaintiffs contest the “Suspended State” mechanism, which allows the DGII to suspend a taxpayer's RNC if they fail to file declarations or make payments during certain periods.

The petitioners argue that this measure restricts economic and administrative activities for both individuals and legal entities. They claim the provision violates several constitutional principles, including legality, due process, freedom of enterprise, and the principle of proportionality. They further assert that the suspension limits the ability to complete official procedures and affects the regular use of fiscal vouchers.