12 May 2022

Puerto Rico’s Municipal Revenue Collections Center extends due date for filing personal property tax return for tax year 2021 to 23 May 2022

In Administrative Order (AO) 2022-002, the Puerto Rico Municipal Revenue Collections Center (CRIM) has extended the due date for filing the personal property income tax return for tax year 2021 from 15 May 2022 to 23 May 2022.

Taxpayers required to make estimated tax payments will need to pay the fourth quarter installment for tax year 2021 by 23 May 2022, to receive a 5% discount on the personal property income tax due for 2021. Taxpayers that make the fourth quarter payment also will receive an automatic extension of time to file the return.  Taxpayers that are not required to make estimated tax payments and have a 2021 personal property tax balance due will need to make the payment by 23 May 2022.

When making the fourth quarter payment, taxpayers should verify that they have paid 100% or more of the tax determined on the personal property income tax return for tax year 2020. At the time of filing the return, taxpayers that have paid 100% of the tax determined in year 2020 through their estimated tax payments will qualify for the 5% discount.

Taxpayers with a volume of business of $3 million or more have until 16 August 2022, to file their personal property income tax returns and audited financial statements or other required documents. Taxpayers that cannot comply with the filing requirements must submit the personal property income tax return with a letter or attachment signed by a CPA indicating that the audited financial statements and supplementary information or agreed upon procedures report, as applicable, have not been completed. For the return to be considered as timely filed, the taxpayer must submit the required information no later than 22 November 2022.

Implications

CRIM eliminated the “create an extension” option from its portal. AO 2022-002 specifically provides that taxpayers with a balance due will need to pay it by 23 May 2022 as a fourth quarter estimated tax payment; in those instances, the payment will automatically grant the taxpayer an extension of time to file the return. However, AO 2022-002 is silent on what happens if the taxpayer already covered its tax liability with (1) an overpayment from the previous year, (2) estimated tax payments made in the first through third quarters, or (3) a combination of both.

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For additional information with respect to this Alert, please contact the following:

Ernst & Young Puerto Rico LLC, State and Local Taxation Group, San Juan

Document ID: 2022-5476