Puerto Rico Issues Determination on Relief from Disallowance of Deductions When Transfer Pricing Study is Prepared
Puerto Rico's Treasury Department has issued Administrative Determination (AD) No. 21-05 of 11 May 2021, which provides new guidance regarding the general 51% disallowance of deductions for cross-border expenses incurred with related persons not engaged in trade or business in Puerto Rico. In this respect, it is provided that the relief from the 51% disallowance is provided when a deduction is…
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