When I started building companies in Africa and Europe, one assumption never crossed my mind: that if I registered a company, I could send my customers an invoice. Of course I could. An invoice is the most basic act of commerce. I sell, I bill, I get paid.
Then I started doing business in the Dominican Republic, and I learned that this is not how it works here.
The invoice is not yours. It belongs to the tax authority.
In the Dominican Republic, every valid invoice must carry a fiscal receipt number, the NCF. Those numbers are not generated by your own accounting system. They are issued in sequences, and the DGII, the tax authority, authorizes how many you receive. You open a company, you register it, and then you ask the state for permission to bill. The authority looks at your profile and decides what range of numbers you are allowed to use. When you run out, you ask again.
Read that again. The government does not only tax your revenue after you earn it. It sets a ceiling on how much commercial activity you can formally document in the first place.
Why this is a problem for entrepreneurs
1. It inverts the burden of proof. In a free market, you act and the state intervenes only when you break a rule. Here, you must be pre-approved before you can act at scale. The founder is presumed to be a risk until the authority is comfortable. Nobody should need a permit to send a bill.
2. It punishes exactly the companies that grow fast. A startup does not grow in a straight line. A good month can be ten times a quiet one. If your authorized sequence is sized for your past, your success becomes an administrative emergency. You are ready to sell, the customer is ready to pay, and you are waiting for a bureaucratic approval to issue the document that makes the sale legal.
3. It makes formality more expensive than informality. We say we want small businesses to formalize. But when formalizing means you are rationed on how much you can bill, the rational choice for many people is to stay outside the system. A state that wants a bigger tax base should make it effortless to be inside it, not make the people who comply wait in line for the right to operate.
4. It concentrates discretion in the wrong place. Whenever a civil servant decides how much you may do, you have created a relationship of dependence. Even if every official acts in good faith, the system rewards the entrepreneur with patience, connections and a good accountant, and it penalizes the one who has none of those. That is not a level playing field.
The anti-liberal logic behind it
I understand the intention. The authority wants to fight tax evasion and fictitious invoicing, and that is a legitimate goal. But the method matters. Controlling the supply of invoice numbers is a way of managing the entrepreneur before anything has gone wrong. It treats every company as a potential fraud and asks it to prove otherwise, one sequence at a time.
There are better ways to achieve the same goal. In much of the world, including the United States, you issue invoices freely and the state audits afterwards, using data, reporting and penalties for real abuse. The freedom to bill comes first, and accountability follows. The Dominican approach flips that order, and the result is a system in which economic freedom is something the state grants, in installments, rather than something the entrepreneur simply has.
Electronic invoicing is moving the country in a more modern direction, and I welcome it. Digital reporting gives the authority real-time visibility, which is exactly the argument for removing the ceiling. If the state can see every transaction as it happens, it no longer needs to ration the paper.
What I think should change
- A registered company should be able to issue as many invoices as its business requires, with no prior authorization of quantity.
- Oversight should be based on transparency and after-the-fact audit, not on quotas set in advance.
- Penalties should target real fraud, not the ordinary growth of a legitimate business.
- Every procedure that blocks a company from selling should have a short, fixed and published response time.
Why I’m writing this
I love building in the Dominican Republic. The Samaná Peninsula is one of the most promising places I have ever worked, and the country has every ingredient to become a regional hub for entrepreneurs: talent, location, energy. But a country competes for founders not only with beaches and incentives. It competes with how it treats someone on the day they try to make their first sale.
If we want more companies, more jobs and more formal tax revenue, the simplest policy is the one that sounds almost too obvious: let entrepreneurs invoice. Freedom to trade starts with the freedom to bill.
Marek Zmysłowski
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