On June 30, 2022, the Government of Puerto Rico enacted Act
52-2022 ("Act 52"), known as the "Puerto Rico Public
Finance Stability Act", creating a new tax framework for
companies that had been subjected to the Act 154 tax regime. Among
other items, Act 52 also introduced new requirements and
limitations on the availability and claiming of tax credits.
Act 52 added a new Section 1051.16 to the Puerto Rico Internal
Revenue Code of 2011 authorizing the creation of a new Tax Credits
Management System ("MCC", for its Spanish acronym) within
the Puerto Rico Treasury Department. Administrative Determination
No.
22-11 ("AD 22-11") set January 1, 2023, as the
effective date for the implementation of the MCC although taxpayers
will be to able access it through the Unified Internal Revenue
System (SURI) starting January 18, 2023. No agency shall grant or
issue tax credits between January 1, 2023 and January 17, 2023.
