Tax due dates extended as Puerto Rico Governor declares state of emergency following the spread of Coronavirus (COVID-19)

Following Puerto Rico Governor's declaration of state of emergency for the island (through Executive Order No. OE-2020-020), the Puerto Rico Treasury Department (PRTD) issued several guidelines to extend certain due dates for filing tax returns and for effecting certain payments. 

Subsequently, the Puerto Rico Department of State (DoS) issued an extension to the filing due date of the 2019 Annual Report. 

PRTD due date extension guidelines

  • Administrative Determination 20-03 (AD 20-03)

Through AD 20-03, the PRTD extends the due dates of certain tax returns, without the need of filing an automatic request for extension of time.

AD 20-03 also extends the corresponding payment of taxes for such returns and the payment of the first installment of the estimated tax that must be filed and paid, for tax year 2020. It enumerates the extensions between March due dates and April due dates, as follows:

  1.  March Due Dates
Tax Return/Payment/
Taxpayer		 Original Due Date New Filing Due Date New Payment and Estimated Tax  for First Installment Due Date
Pass-Through Entities (Partnerships, COIs, Special Partnerships, Employees-owned Special Corporations, Revocable Trusts or Grantor Trusts) March 16, 2020   April 15, 2020 April 15, 2020
Return and Estimated tax payment for every taxpayer with an economic year with an original due date in March 16 March 16, 2020 April 15, 2020 April 15, 2020
Return, Form, Declaration, Payment or other transaction related to income tax, whose due date fell between February 12 and February 24, 2020 March 16, 2020 (Due to IB 20-02) April 15, 2020 April 15, 2020

 

      2.  April Due Dates  

Tax Return/Payment/ Taxpayer Original Due Date New Filing Due Date New Payment and Estimated Tax for First Installment Due Date
Every Tax Return (or Extension of Tax Return) originally due on April 15 April 15, 2020 May 15, 2020 May 15, 2020

 

  • Internal Revenue Informative Bulletin 20-07 (IB 20-07)

IB 20-07 complements AD 20-03, and provides certain extensions for administrative processes available for a taxpayer against the PRTD, the majority of which were performed physically through a visit to the PRTD.

  • Notifications for Mathematical Error or Adjustment of Tax Return (Notification)
    • An extension of an additional one hundred and twenty (120) days is granted to the period established on every Notification.
  • Office of Administrative Appellations (OAA, for its Spanish acronym)
    • Every term available to file an administrative claim and every term required to present information and/or documentation requested by the OAA, will be extended for 90 days, starting on the due date, if the due date is after March 12, 2020.
    • Every OAA hearing scheduled between March 16, 2020, and June 15, 2020, will be automatically suspended. The OAA will eventually inform the taxpayer of the new hearing date.

  • Administrative Determination 20-05 (AD 20-05)

AD 20-05 was published to address additional due dates administered by the PRTD, as follows:

Sales and Use Tax (SUT)

Tax Return Original Due Date New Due Date (Filing and Payment) or New Rules
Monthly SUT Return for February 2020 March 20, 2020 April 20, 2020
Bi-Monthly SUT Deposits March 15 & March 31 No penalties imposed if such deposits were not made, but SUT was covered with the Monthly SUT Return (regular rule).

 

Other Tax Returns, Forms and Declarations (Not related to income taxes)

Tax Return Original Due Date New Due Date (Filing and Payment)
Other tax returns, forms and declarations, not related to income Between March 15, 2020 & April 15, 2020 Original due date + One month (without filing an extension)

 

PRTD Bonds

PRTD Bonds Original Expiration Date New Automatic Expiration Date
Every Bond with the PRTD Between March 15 and March 31, 2020 April 30, 2020

 

Internal Revenue Licenses

Licenses Original Expiration Date New Automatic Expiration Date
Every Internal Revenue License Between March 15 and March  31, 2020 April 30, 2020

 

  • Internal Revenue Informative Bulletin 20-08 (IB 20-08)

IB 20-08 provides a relief for penalties related to the filing requirement of Informative Declarations under the original due dates, corresponding to tax year 2019, if said Informative Declarations are completed through SURI no later than April 15, 2020.

Department of State Extension Guidelines

The Puerto Rico Department of State published certain extensions for annual reports that must be filed by entities for calendar year 2019.

The new due dates apply as follows:

  • 2019 Annual Reports are automatically extended and are now due on May 15, 2020
  • 2019 Annual Report Extension extends the Annual Report's due date until June 15, 2020
    • The extension may be requested by making an advance payment of the Annual Report fee before May 15, 2020. The entity is still required to file the report by June 15, 2020 to avoid penalties.
  • 2019 Additional Extension may be filed between April 16, 2020, and June 15, 2020, if the entity has prepaid the Annual Report. This additional extension will be valid until July 15, 2020.

Our tax advisors can advise you regarding the filing extensions following the State of Emergency Declaration in Puerto Rico. Please contact us at (787) 751-6164 | [email protected] for help or more information.

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