Ferraiuoli’s Tax Incentives & Credits Practice provides advice to clients in the United States and Puerto Rico to assist them in developing effective tax planning strategies that will minimize the tax costs of doing business in Puerto Rico.
This team has extensively advised our clients in connection with:
- Act No. 73 of May 28 of 2008, known as the “Puerto Rico Development Economic Incentives Act” (and the prior Act No. 135 of December 2, 1997)
- Act No. 20 of January 17, 2012, known as the “Export Service Promotion Act”
- Act No. 22 of January 17, 2012, known as the “Individual Investors Act”
- Act No. 27 of March 4, 2011, known as the “Puerto Rico Film Industry Economic Incentives Act”
- Act No. 83 of July 19, 2010, known as the “Green Energy Incentives Act”
- Act No. 74 of July 10, 2010 known as the “Tourism Development Act”
Our Tax Practice Group attorneys have extensive knowledge and experience working with all of Puerto Rico’s tax credit and tax incentives programs. We have successfully negotiated and monetized multiple tax credit and tax exemptions grants under the various tax exemption laws and regulations currently available in Puerto Rico for specific activities and industries including traditional and niche manufacturing, research and development, key supplier services, export services, tourism, film, energy, and recycling, among others.
Our legal professionals bring with them strong professional relationships and prior work experience with all of the relevant local agencies involved in the evaluation and certification of tax credits and grants, including the:
- Puerto Rico Treasury Department
- Puerto Rico Tourism Company
- Puerto Rico Industrial Development Company
- Puerto Rico Film Commission
- Department of Economic Development and Commerce
- Office of Industrial Tax Exemption
Our attorneys are frequent speakers and moderators at conventions, seminars and events organized and sponsored by the principal trade associations, economic development initiatives, and technology incubators on the Island including the Puerto Rico Manufacturers Association, the Puerto Rico Chamber of Commerce, the Puerto Rico Investment Summit, and several others.
Recognition:
- Since 2012, the Tax Practice Group has been ranked as one of the leading tax law groups in Puerto Rico according to Chambers & Partner’s Global and Latin America Guides.
Representative Matters and Transactions:
- Represented local and multinational entities in the successful approval of new decrees, renegotiations and amendments for traditional and niche manufacturing, key supplier services and other industries.
- Assisted various local service providers to pharmaceutical multinational companies in obtaining tax exemption grants as key suppliers in the validation, quality control, project engineering and inspection industries.
- Successfully prepared application documents and obtained government approval for approximately $7,000,000 in Film Tax Credits, including groundbreaking transactions representing the first time that film incentives under Act #27 were granted to television programs, live recording projects, and live streaming projects.
- Successfully prepared application documents and obtained government approval of Film Tax Credits for multiple live recording events and festivals held within Puerto Rico.
- Successfully prepared application documents and obtained government approval of Research & Development Tax Credits for multiple proprietary software developers operating within Puerto Rico.
- Successfully structured multiple acquisitions of distressed Puerto Rico manufacturing facilities in order to meet the legal and regulatory requirements of the Industrial Investment Credit to manufacturing facilities in the process of shutting down Puerto Rico operations.
- Advised multiple green energy producers in the negotiation of Green Energy Tax Exemption Grants and in the proper structuring of Puerto Rico energy projects in order to meet the requirements to claim the Investment Tax Credit under the Federal Internal Revenue Code.