Tax Watch



For additional information, do not hesitate to contact our offices. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507.


We welcome your questions and comments.


Myrna Y. Medina-Massanet

(787) 759-3830






*Special Tax Counsel



Tax Watch – Reinstatement of the Procedure For the Filing and the Payment of the Sales and Use Tax on Imported Goods Introduced by Bonded Merchants


On November 6, 2014, the Puerto Rico Treasury Department (“PR Treasury”) issued Administrative Determination 14-27 (“AD 14-27”) which reinstates for bonded merchants only the procedure to obtain the release of property imported to Puerto Rico established in Internal Revenue Circular Letter 14-06 (“IRCL 14-06”), effective as of November 18, 2014.


As reported on our August 7, 2014 Tax Watch, the release process set forth by IRCL 14-06 was suspended by Administrative Determination 14-15 (AD 14-15) which established a temporary procedure and automatic release to property imported to Puerto Rico.


Effective November 18, 2014, property imported to Puerto Rico by bonded merchants will be subject to the release process established in IRCL 14-06.


Accordingly, effective November 18, 2014, every bonded merchant must file a Tax Declaration of Imports (i.e. Form 2970) through the PICO system in order for the PR Treasury to authorize the release of the property imported to Puerto Rico. The release authorization should be issued by the PICO system by issuing Form SC 2015A. In addition, bonded merchants will be required to file the Tax on Imports Monthly Return (i.e. Form 2915.1D), and remit the use tax payment through the PICO portal on or before the 10th of the following month in which the property is imported.


Bonded taxpayers must file the Complementary Declaration for all Automatic Releases of Merchandise Imported between November 1 and 17 no later than December 10, 2014 and before filing the Tax on Imports Monthly Return.


The temporary procedure established by AD 14-15 and summarized in our Tax Watch published on August 7, 2014 shall remain effective after November 17, 2014 for importers that are not bonded merchants until the PR Treasury issues any further guidance.


***IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any United States federal tax advice in this communication (including any attachments) is not intended or written by Fiddler González & Rodríguez, P.S.C. to be used, and cannot be used, for the purpose of (i) avoiding any penalties under the Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. **


**©2014 Fiddler, González & Rodríguez, P.S.C. This Watch has been prepared by Fiddler, González & Rodríguez, P.S.C. for informational purposes only and does not constitute legal advice. This information does not create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this without seeking advice from professional advisers. Fiddler, González & Rodríguez, P.S.C. and its members assume no responsibility to inform you of additional changes in law or any other legal issues related to the matters advised in this e-mail.


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