The Global Minimum Tax and its Effects on Puerto Rico: A Window of Opportunity

Espacios Abiertos (EA)
Description:

This report, prepared by Open Spaces (EA), analyzes the effects of the 15% Global Minimum Tax (IMG) in Puerto Rico, evaluating both the opportunities and the risks it presents. The digitalization and globalization of the economy have allowed multinationals to transfer profits to low-tax jurisdictions, resulting in the loss of significant tax revenues worldwide. This situation has led more than 140 jurisdictions to cooperate to implement an IMG that guarantees more equitable and sufficient taxation to finance essential public services. The OECD and the G-20 have developed the inclusive BEPS framework, with 147 economies committed to reforming international taxation through two pillars. Pillar I seeks to reassign tax rights on the profits of large multinationals to the markets where they sell. Pillar II, which includes the Global Minimum Tax (IMG) and the Subject to Taxation Clause (CSI), establishes a minimum tax of 15% for multinationals with consolidated annual revenues exceeding 750 million euros. This report focuses on Pillar II and its implications for Puerto Rico. Puerto Rico has historically used its limited contributory autonomy to attract investment through tax incentives and tax decrees. On the other hand, the federal government has led contributory policies such as the defunct Section 936. The removal of this section resulted in a decline in investment and employment on the island. In response, laws such as Act 154 of 2010 and Act 52 of 2022 were enacted to stabilize local tax policy. The implementation of the IMG in Puerto Rico could significantly increase tax revenues in the short term, but it also presents long-term risks if the island does not adapt its economic model to mitigate these impacts.

Objective:

Analyze the effects, opportunities and risks of the 15% Global Minimum Tax (IMG) in Puerto Rico, focusing on Pillar II of the BEPS framework.

Main Variables
Global Minimum Tax, incentives, Global Minimum Tax
Frequency of release of the report:
Reference Population:
Multinational companies with consolidated annual revenues of more than 750 million euros that operate in Puerto Rico.
Product:
El Impuesto Mínimo Global y sus efectos en Puerto Rico: una ventana de oportunidad
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Economy and Finance
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Espacios Abiertos (EA)
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