Puerto Rico’s Treasury Department clarifies guidance on transfer pricing studies and certification required with income tax return

The Puerto Rico Treasury Department (PRTD) has clarified (Administrative Determination (AD) 21-08) prior guidance in AD 21-05 on submitting transfer pricing studies.

In AD 21-05, the PRTD stated that taxpayers had to file Form 6175, "Certification of Compliance with Sections 1033.17(a)(16) and (17) of the Code," within 30 calendar days of a request. AD 21-08 clarifies that the transfer pricing study, not Form 6175, must be submitted to the PRTD within 30 days of a request. The PRTD also clarifies…