The Treasury Department of Puerto Rico issued a “Circular Letter of Tax Policy” No. 16-06 (October 3, 2016) that establishes general procedures for the public release of taxpayer rulings and administrative determination letters on a “no name” or anonymous basis.
Historically, the practice of the Puerto Rico Treasury Department (PRTD) has been to answer inquiries of taxpayers and other interested parties, whenever appropriate in the interest of sound tax administration, as to the tax effects of their transactions by “private rulings.”
Guidance issued in 1999 (Circular Letter No. 99-01) establish what was then a general procedure for the issuance of formal responses to taxpayer inquiries, in the form of rulings and administrative determination letters.
In an effort to allow for disclosure of official interpretations by the PRTD as to the application of the Puerto Rico tax law, Circular Letter No. 16-06 was issued to amend Circular Letter No. 99-01. The new guidance provides that in the interest of sound public policy, rulings and administrative determination letters issued privately to taxpayers—such private rulings—will be made publicly available on a “no name” basis.
The new circular establishes the procedures to be followed by taxpayers and the PRTD in releasing the ruling letter to the public, including that:
For more information, contact a KPMG tax professional in Puerto Rico:
Rolando Lopez | +1 (787) 756-6020 | firstname.lastname@example.org
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