Americas

Puerto Rico

Corporate rate
37.5%
Top personal rate
33%
VAT / GST rate
11.5%
One-sentence summary Puerto Rico's corporate tax position: 37.5 (18.5% + 19% surtax over USD 275,000). Personal income tax: 33 plus 5% gradual adjustment tax. VAT/consumption tax: 11.5 tangible property/services; 4 B2B/designated services.

Corporate Tax Rate

Puerto Rico's headline corporate income tax (CIT) rate is 37.5 (18.5% + 19% surtax over USD 275,000).

Personal Tax Rate

The headline personal income tax (PIT) rate is 33 plus 5% gradual adjustment tax.

VAT / GST Rate

The standard VAT/GST (or equivalent consumption tax) rate is 11.5 tangible property/services; 4 B2B/designated services. Registration thresholds, zero-rated and exempt categories, and reduced rates vary by jurisdiction - see the source link below for the full detail on this jurisdiction.

Residency

Puerto Rico is an unincorporated US territory with its own local Internal Revenue Code (Act 1-2011, as amended) that operates alongside, not instead of, the US federal tax code - this dual-layer structure is the single most important thing to understand before applying any other section on this page. Individual residency for federal tax purposes turns on the IRC Section 937 "bona fide resident" test, applied by the IRS in three parts: (1) physical presence of at least 183 days in Puerto Rico during the tax year; (2) a closer connection to Puerto Rico than to any US state or foreign country; and (3) Puerto Rico as the individual's tax home. Under IRC Section 933, a bona fide resident of Puerto Rico for an entire tax year excludes Puerto Rico-source income from US federal gross income entirely - this is the statutory foundation underneath Puerto Rico's well-known tax incentive programs. A Puerto Rico corporation is resident for local PR tax purposes if organized under Puerto Rico law.

CFC (Controlled Foreign Company) Rules: No (locally) / Yes (US federal overlay)

Puerto Rico's own local tax code does not operate a CFC-style attribution regime of the kind sovereign countries use, because it isn't taxing worldwide income against a foreign-subsidiary backdrop - PR sources and taxes income under its own code, layered under the federal system. The relevant CFC exposure is entirely a matter of US federal law: a Puerto Rico corporation counts as a Controlled Foreign Corporation under IRC Subpart F/GILTI if more than 50% owned (by vote or value) by "United States shareholders," which would ordinarily expose a mainland US owner to GILTI inclusion (a minimum federal rate of 10.5%, up to 21%) on top of Puerto Rico's own corporate rate. Critically, an individual who is a genuine bona fide resident of Puerto Rico and owns a Puerto Rico corporation qualifies for a specific federal exemption from CFC and PFIC treatment with respect to that PR corporation - confirmed via a US federal tax planning source addressing this exact fact pattern. If a mainland US resident co-owns more than 50% of the same entity, the full CFC/GILTI exposure reattaches for that mainland owner's share.

Thin Capitalization

Puerto Rico's local Internal Revenue Code does not impose a general debt-to-equity ratio cap on interest deductibility. It does contain a targeted anti-abuse sourcing rule for interest paid to certain related foreign corporations: interest received from a foreign corporation, or from a domestic (Puerto Rico) corporation that is not a commercial bank, is only treated as non-Puerto-Rico-source (and thus outside the payee's PR tax net) if the payer can demonstrate that less than 20% of its gross income over the prior three years was Puerto Rico-source - a base-protection mechanism aimed at cross-border interest income sourcing rather than a debt/equity ratio limitation on the borrower's deduction.

Foreign Bank Account / Foreign Financial Asset Reporting

Because Puerto Rico is a US territory rather than a foreign jurisdiction, there is no separate Puerto Rico FBAR-equivalent - Puerto Rico bona fide residents who are US citizens remain fully subject to the same federal FinCEN Form 114 (FBAR) and Form 8938 obligations as any other US person once foreign (non-US, non-PR) accounts exceed the applicable thresholds. Puerto Rico itself, as part of the United States for FATCA purposes, is not a separate FATCA IGA jurisdiction and does not have its own CRS participation status distinct from the US.

Treaty Network

Puerto Rico is not itself a party to any bilateral US income tax treaty - Puerto Rico residents generally cannot claim benefits under US tax treaties with foreign countries, since Puerto Rico is treated as US territory for treaty purposes but PR-source income is typically outside the federal tax base entirely for bona fide residents under Section 933 rather than being addressed through treaty relief. Confirm the specific treatment of any foreign-source income with a US international tax advisor, since the interaction between Section 933, GILTI, Subpart F, and any relevant US tax treaty is highly fact-specific and was significantly reshaped by 2017 US federal tax reform (introduction of GILTI) and by Puerto Rico's own 2026 Incentives Code reform (Act 38-2026).

Sources: PwC Worldwide Tax Summaries - Puerto Rico, Puerto Rico Territory Authority - Act 60, Federal Tax Treatment, and Business Incentives (IRC 937 bona fide residence test, GILTI interaction), San Francisco Tax Lawyers - Puerto Rico bona fide resident CFC/PFIC federal exemption, Puerto Rico Internal Revenue Code of 2011, Section 30151 - Income from sources within Puerto Rico (20% foreign-source interest sourcing test), Ipanema Partners - Puerto Rico Act 60 in 2026 (Act 38-2026 reform). Rates last reviewed by PwC: 10 March 2026. Page last verified: August 08, 2026. General information only - confirm current rates and any specific position with a licensed advisor in this jurisdiction before relying on this page.