Act 60 · Incentives Code

The 2012 laws, rewritten.

Act 20 pulled export-services companies. Act 22 pulled new residents. Act 60-2019 put both in one code. Act 38-2026 changed the individual-investor rate for applications filed from 2027.

Time-sensitive

Individual-investor applications filed on or before December 31, 2026 are generally grandfathered under the prior 0% rules through 2035. The filing date — not the move-in date — is what matters.

From 20 and 22 to 60

Public Law 20 of 2012 created tax incentives for companies that establish eligible export-services businesses on the island. Public Law 22 of 2012 sought new residents by exempting particular gains realized or accrued after the individual became a Puerto Rico resident. Those were the statutes on the original Omnia site.

On July 1, 2019 Puerto Rico consolidated dozens of incentive statutes into Act 60, the Incentives Code, effective January 1, 2020. Chapter 3 is the successor to Act 20. Chapter 2 is the successor to Act 22. The benefits survived; the paperwork, the charitable-contribution rules, and the substance tests got stricter.

On March 10, 2026, Governor Jenniffer González-Colón signed Act 38-2026. It extended the individual-investor program to 2055 and replaced the 0% rate for new applicants with a 4% Puerto Rico tax on interest, dividends, and post-residency capital gains — unless the application is filed by the end of 2026.

Chapter 3

Export services

Formerly Act 20 of 2012

For businesses that operate from Puerto Rico and sell eligible services to clients located outside the island. Act 38-2026 did not change this chapter.

4% fixed Puerto Rico income tax on eligible export-services income, versus ordinary corporate rates that can reach the mid-30s.
100% Puerto Rico exemption on dividends or profit distributions from the exempt operation.
Property and municipal-tax relief on assets and volume tied to the exempt activity.
Substance. A real office, real work, and services actually exported. Remote theater is not the product.

Typical eligible work includes consulting, software, marketing, research, professional services, and other categories listed in the regulations — always to customers outside Puerto Rico.

Chapter 2

Individual investors

Formerly Act 22 of 2012

For people who become bona fide residents and whose relevant income is investment income — gains, dividends, interest — rather than a mainland salary.

Filed by December 31, 2026: generally 0% Puerto Rico tax on interest, dividends, and post-residency capital gains through December 31, 2035.
Filed from January 1, 2027: generally 4% on those items through 2055, plus a rolling six-year prior non-residency lookback and tighter home-ownership rules.
Bona fide residency under the IRS three-part test from day one. Pre-move appreciation has its own, less generous, rules.
Ongoing obligations: primary residence (typically within two years) and the annual charitable contribution, due before January 1.

What we will not tell you

We will not say that Puerto Rico is a 0% federal-tax jurisdiction for all income. It is not. IRC §933 reaches Puerto Rico–source income of bona fide residents. Mainland-source wages, U.S. business income, and many pre-move gains remain in the federal system.

We will not treat a decree as a substitute for living here. The original Acts 20 and 22 were sold, in some circles, as a paper exercise. That era is over. Omnia’s job is the opposite: make the move real enough that the decree holds.

Item	Chapter 3	Chapter 2
Who it is for	Export-services businesses	New resident investors
Puerto Rico rate	4% on eligible income	0% if filed in 2026; 4% from 2027
Federal overlay	§933 on PR-source, if you are a bona fide resident	Same — residency is the gate
Act 38-2026	Unchanged	Extended to 2055; rate change for new filings

Before January 1

Give through Gaudium

The annual charitable contribution on an individual-investor decree is due before January 1 each year. Omnia supports Gaudium et Spes Foundation. Make the gift there and keep the receipt with the decree file.

Donate at gaudiumspes.org

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