Puerto Rico May Impose A 15% Minimum Tax On Business Income; What Will Happen To Act 60 Decrees?

• Published date: 19 February 2024
• Law Firm: Caplin & Drysdale
• Author: Mr J. Clark Armitage, H. David Rosenbloom, Elizabeth Stevens, Heather D. Schafroth, Benjamin M. Satterthwaite and Arjun Ghosh

The Organization for Economic Cooperation and Development (OECD), of which the United States is a member, has proposed a 15% minimum global tax on business income. Over 140 countries have agreed to implement some form of the proposal (referred to as "Pillar II"). While the United States has agreed in principle to adopt Pillar II, it has not taken steps to do so and likely cannot do so for some years. Puerto Rico has gone further. It has agreed in principle to adopt Pillar II, has formed a commission and solicited applications from outside advisors on how best to implement Pillar II. If Puerto Rico implements Pillar II in its proposed...