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Puerto Rico Services

TP Analytics is well-versed in assisting businesses and individuals who are Puerto Rican tax residents and beneficiaries of export services incentives (Act 60 and historical Act 20 decrees) with transfer pricing economics. We have provided transfer pricing economics support across various industries to companies running from $4 million in annual revenues to over $500 million.

Transfer pricing economics is a key and critical aspect of relocating to Puerto Rico. Puerto Rico’s export service incentives are often awarded to individuals or companies that have transactions with pre-existing US operations. Transfer pricing rules apply to transactions involving Puerto Rican corporations or Puerto Rican tax residents who have mainland U.S. operations under common control. Our transfer pricing economics services can help determine and evaluate the “arm’s length price” for transactions between Puerto Rico, the U.S., or other jurisdictions.

Our typical services for beneficiaries of Puerto Rican export services incentives include:

● Pre-move planning: Tax savings from moving to Puerto Rico can be estimated in advance of the move. We analyze possible transactions between PR entiti(es) and US mainland operations.
● Planning: Determining arm’s length pricing for intercompany transactions. This often includes analyzing arm’s length pricing for Executive Services, PR staffing services, and Buy-Sell pricing analysis. We tailor our analyses considering the transfer pricing regulations and the facts and circumstances of the transactions.
● Documentation: Preparing contemporaneous transfer pricing documentation that satisfies US Section 6662(e) requirements. Documentation provides an analysis of whether historical transfer prices are arm’s length. Contemporaneously prepared transfer pricing documentation can provide penalty protection.