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2026 filing windowApplications filed by 31 Dec 2026 may still lock the 0% individual rate. From 2027, new decrees generally move to 4%.

See the rules
Castillo San Felipe del Morro, Old San Juan

Puerto Rico · Act 60 specialists

Act 60 focused tax experts.

We file and keep Act 60 decrees for investors and export companies. Most export files qualify for 2%, not 4%. Applications we have filed have been approved 100% of the time — then we stay on the file so Hacienda and the IRS do not become a surprise.

2%

Export rate, first 5 years, volume ≤ $3M

0%

Individual rate if filed in 2026

100%

Approval on applications we filed

3,899

Export-service decrees granted in PR, 2012–2024

The Incentives Code

Two doors. One firm that knows both.

Act 60-2019 folded the old Act 22 and Act 20 regimes into a single code. Most clients need one chapter. Serious operators often need both — and the federal residency tests that sit underneath.

Chapter 2 · formerly Act 22

Resident individual investor

For U.S. persons who become bona fide residents of Puerto Rico. Interest, dividends, and post-move capital gains can be taxed at 0% if the decree is filed in 2026 — or 4% for applications filed from 2027 under Act 38-2026.

  • Bona fide residency: presence, tax home, closer connection
  • Built-in gains before the move stay in the U.S. system
  • Annual giving and principal-residence conditions apply
Read the individual path

Chapter 3 · formerly Act 20

Export of services

Eligible services performed from a bona fide Puerto Rico office for clients with no island nexus — consulting, software, finance, creative, and other DDEC-approved work. The headline rate is 4%. The rate most companies actually take is 2% for the first five years when annual business volume is $3 million or less.

  • 2% for five years if volume is $3M or less; 4% thereafter (4% from day one above $3M)
  • 100% exemption on distributions from the exempt business
  • 100% property-tax relief for five years at the small-volume tier, then 75%
  • Substance: real office, real work, real export clients
Read the export path

How we work

Decree first. Compliance always.

  1. 01

    Pre-move map

    Federal, state, and Puerto Rico picture before you change your tax home — including built-in gains and what does not move with you.

  2. 02

    Structure

    Entity, decree chapter, and how you pay yourself. For export companies we also lock the volume test — $3 million or less is 2% for five years, and that is where most files sit. 1099 versus W-2 is an audit fact, not a preference.

  3. 03

    File and negotiate

    Applications, supporting evidence, and the grant itself. We stay in the file until DDEC issues.

  4. 04

    Live the tests

    183 days, tax home, closer connection — documented, not assumed. Annual accounting and the $10,000 contribution.

The island, in numbers

This incentive already moved thousands of files.

Act 60 is not a rumor. DDEC has been granting export-service and resident-investor decrees for more than a decade. The 2% band is where most operating companies actually sit.

  • 2%

    First-five-year export rate when annual volume is $3 million or less — the tier most businesses qualify for.

  • 100%

    Approval on Act 60 applications Bonn LLC has filed. Not a government guarantee — our record.

  • 3,899

    Export-service decrees granted in Puerto Rico from 2012 through 2024 (DDEC / GAO).

  • 5,852

    Resident-investor decrees in the same window. Not everyone who holds a decree has relocated — the ones who live the tests keep the benefit.

Decree counts: Puerto Rico DDEC data as reported by the U.S. Government Accountability Office (GAO-26-107225), 2012–2024. Approval rate is Bonn LLC’s filing record.

Practice

What the engagement actually covers

All services

Pre-move tax analysis

Federal, state, and Puerto Rico income in one picture, before you relocate.

Decree strategy

Act 60 chapters, stacked credits, and the grant we can actually defend.

Entities and payroll

Formation, export-company substance, and how compensation is reported.

Residency evidence

Presence, tax home, and closer-connection files the IRS already asks for.

Accounting

Books, 480s, and the annual work that keeps the decree alive.

Audit readiness

The IRS has campaigns on Act 60 residents. We keep the file ready.

Working read

Is Act 60 even the right tool?

Five questions. A directional read — not a determination, and not a filing. The consult is where we put numbers on it.

1 / 5

What are you actually trying to do?

From clients

Direct, available, and on the grant.

Want to give a shout out to Amervim Bonano for taking my call today to answer questions and help me understand what to expect with all this 20/22 paperwork. Highly recommend him.

R. Stefanski

Act 20 Grant is approved!!! Many thanks to Amervim Bonano, he made this process very, very easy.

Client, export services

We just got off a call with Amervim Bonano. He was very helpful in answering all of our questions. Highly recommend.

Relocating couple

Bring the facts. We will tell you if Act 60 fits.

A consult is a working session, not a pitch. If the profile is wrong for a decree, we say so.