At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Departamento de Hacienda (Puerto Rico Department of the Treasury). Summaries are simplified; check the linked official source before relying on them.
The law
#Puerto Rico has its own income tax code, the Puerto Rico Internal Revenue Code of 2011 (Act 1-2011, the Codigo de Rentas Internas), run by Hacienda. It is separate from the US federal Internal Revenue Code. Puerto Rico taxes the US as a foreign jurisdiction, and the US Form 8975 rules treat Puerto Rico as its own tax jurisdiction, so a group with a Puerto Rico entity can face the US rules on this site (s. 482, Forms 5472 and 5471) and the Puerto Rico rules at once. Section 1040.09 lets the Secretary of the Treasury allocate gross income, deductions, credits and allowances among related or commonly controlled businesses to stop tax evasion or to reflect income clearly, and to impute income. The section does not say 'arm's length' or list methods; Administrative Determination 21-05 (11 May 2021) ties Puerto Rico transfer pricing to US IRC s. 482 and 26 CFR 1.482-2 to 1.482-9.
Documentation
#There is no stand-alone Master File or Local File. The practical rule is in s. 1033.17(a)(17): 51% of expenses paid to a related person that does not do business in Puerto Rico (or to a foreign home office of a branch) is not deductible (s. 1033.17(a)(16) sets the same limit for pass-through entities paying owners of 50% or more) unless the taxpayer has a transfer pricing study, prepared under s. 482, that exists when the return is filed (tax years starting after 31 December 2018). The taxpayer files Form AS 6175 (also called SC 6175), a certification signed under penalty of perjury, as evidence with the return, and gives Hacienda the study itself within 30 days of a request (DA 21-05 as amended by DA 21-08). The limit does not apply to income covered by an exemption decree. Separately, s. 1061.15 requires financial statements with the return: audited statements at USD 10 million of volume of business or more, and audited statements or an agreed-upon procedures (AUP) report from USD 3 million to under USD 10 million. Related groups add up their volume.
Methods
#The Code lists no methods. DA 21-05 says the methods in 26 CFR 1.482-2 to 1.482-9 are the ones used to test the arm's length standard, so the US best method rule and the other US methods apply by reference. Hacienda has not published its own guidance on arm's length ranges or on the OECD Guidelines. The 2016 proposed regulations under s. 1040.09 that some firms cite were not found as final rules, and the current regulation (Reglamento 8049, compilation of 13 July 2026) has no article that implements s. 1040.09.
Penalties
#No transfer pricing specific penalty was found. The main cost is the loss of 51% of the related-party deduction when there is no qualifying study. A deficiency caused by negligence, substantial understatement or a substantially incorrect valuation carries a 20% addition under s. 6030.03(a), or 40% for gross valuation misstatements. For a corporation, the understatement is substantial if it exceeds the lesser of 10% of the tax required on the return or USD 1,000,000. DA 21-05 says a compliant study lowers the risk of the s. 6030.03 additions. Failing to file a return adds 5% for the first 30 days and 10% for each further 30 days, up to 25% (s. 6030.11(a)), and unpaid tax bears interest at 10% a year (s. 6030.02).
Pillar Two
#Puerto Rico has not enacted Pillar Two. It is not a member of the OECD/G20 Inclusive Framework (Hacienda's own consultation paper says so), and the Code as amended through Act 93-2026 has no IIR, UTPR, QDMTT or GloBE filing. Hacienda ran a public consultation on a QDMTT or alternative minimum tax, with comments due 10 October 2024, and said it was not considering an IIR or UTPR. Minimum tax bills passed by the House in 2023 and 2024 were not enacted, and no law followed. Deloitte's January 2026 summary says Puerto Rico has not committed to GloBE-style rules. Under Act 52-2022 the 10.5% rate on industrial development income for decree holders who elected the new framework would rise to 15% if a US CFC rule imposes a tax of at least 15%; Hacienda said the 2022 US minimum tax did not trigger it (BI RI 22-11). Puerto Rico entities can still be reached by IIR or UTPR top-up tax in other countries.
Other rules
#Corporate income tax is 18.5% plus a surtax of 5% to 19% (top rate 37.5%), with an alternative minimum tax of 18.5%, or 23% at USD 10 million of volume of business or more. Corporations with an Act 60 decree pay a flat 4% or less on eligible income, and their return is due 15 June (s. 1061.16(e)). Act 154-2010 puts a 4% excise tax on related offshore buyers of goods and manufacturing services from large Puerto Rico producers (gross receipts above USD 75 million). Act 52-2022 lets decree holders swap it for a 10.5% income tax on industrial development income. Country-by-country reporting: Puerto Rico has no CbC law. US Form 8975 covers Puerto Rico because a US territory counts as a tax jurisdiction in the report (26 CFR 1.6038-4), and a Puerto Rico parent can name a US entity it controls to file Form 8975 for it. Hacienda gives private rulings and closing agreements, but no APA program was found.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Corporate income tax return (Form 480.2, filed electronically) 15 April for calendar years, or the 15th day of the 4th month after a fiscal year end (s. 1061.16(a)(1)). The automatic extension is 6 months (s. 1061.16(a)(2)(A)); tax is still due on the original date (s. 1061.17). Corporations with an exemption decree under Act 60-2019 or a similar law file later, by 15 June or the 15th day of the 6th month (15 December extended), under s. 1061.16(e); this tool shows the earlier general date. A due date, including an extended one, that falls on a Saturday, Sunday or holiday moves to the next working day (s. 1061.16(c)). Late filing adds 5% plus 10% per further 30 days, up to 25% (s. 6030.11(a)). | Extended: automatic 6-month extension, Form AS 2644 (SC 2644) filed in SURI by the original due date, with the tax paid (e.g. Oct 15, 2026); original due date Apr 15, 2026 | Domestic corporations and foreign corporations engaged in a trade or business in Puerto Rico (including LLCs taxed as corporations). Pass-through entities file by the last day of the 3rd month. | Puerto Rico Internal Revenue Code of 2011, s. 1061.16 (Hacienda); CC RI 26-06 |
| 2 | Financial statements with the return: audited (or an AUP report below USD 10 million) Filed with the return by a CPA licensed in Puerto Rico (s. 1061.15(a)); related groups file combined statements with a column for each member, or separate statements that list the group members. Filing the audit or AUP report also lifts the limits on certain deductions in ss. 1021.02(a)(2) and 1022.04. Where supplementary information is required, the 2025 instructions put it at the last day of the month after the extended return due date (30 November for calendar years). | With Corporate income tax return (Form 480.2, filed electronically) (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | Audited statements for a business with volume of business of USD 10 million or more. From USD 3 million to under USD 10 million, audited statements or an agreed-upon procedures (AUP) report. In a related group with combined volume of USD 10 million or more, each member with USD 3 million or more files audited statements. Under USD 3 million nothing is required. | Puerto Rico Internal Revenue Code of 2011, s. 1061.15; Form 480.2 instructions 2025 |
| 3 | Form AS 6175 (SC 6175) certification: transfer pricing study available (s. 1033.17(a)(16) and (17)) The 2025 Form 480.2 instructions say to submit Form AS 6175 as evidence of the return through SURI and to answer yes to question 19(a). Evidence is due by the 4th business day after the return due date, including extensions; this tool shows the return date. DA 21-08 corrected DA 21-05: the 30 days after a request apply to the study, not to the certification, and the taxpayer signs the certification. | With Corporate income tax return (Form 480.2, filed electronically) (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | Taxpayers who deduct all of the expenses paid to related persons that do not do business in Puerto Rico, or to a foreign home office, and so claim relief from the 51% limit. Not needed for income covered by an exemption decree. | Hacienda DA 21-05 and DA 21-08; Form 480.2 instructions 2025 |
| 4 | Transfer pricing study (s. 482 based) in existence when the return is filed The study must be issued and available when the return is filed (extended date if extended). It must analyse the operations carried out in Puerto Rico and follow s. 482 and 26 CFR 1.482-2 to 1.482-9. An earlier-year study can be relied on if facts and transactions have not substantially changed. Hacienda may deny a study that does not comply. | With Corporate income tax return (Form 480.2, filed electronically) (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | Same taxpayers as the Form AS 6175 certification. Not required by law for anyone else, but it also lowers exposure to the s. 6030.03 additions (DA 21-05). | Hacienda DA 21-05 (transfer pricing studies) |
| 5 | Give the transfer pricing study to Hacienda on request Within 30 calendar days after Hacienda asks for it. The certification states that the study will be filed within that time (DA 21-08 corrected DA 21-05, which had put the 30 days on the certification itself). | Within 30 days of a tax authority request | Taxpayers who signed the Form AS 6175 certification. | Hacienda DA 21-08 (amends DA 21-05) |
Official texts
#- Puerto Rico Internal Revenue Code of 2011 (Act 1-2011), ss. 1010.05(b), 1033.17(a)(17), 1040.09, 1061.16, 6030.03 and 6030.11, Hacienda copy of the OGP compilation (Spanish only, no official English version) (The enacted text of a law is not protected by US copyright (the government edicts doctrine, Georgia v. Public.Resource.Org, 590 U.S. 255 (2020); US Copyright Office Compendium s. 313.6(C)(2) lists legislative enactments of states and territories as not registrable), and US copyright law governs in Puerto Rico. No Puerto Rico statute or site terms page that says otherwise was found. The Hacienda and OGP copies are unofficial compilations: only the statutory words are reused, not their notes.)