Act 65-2025 (the “Act”), signed into law on July 17th, 2025, by Governor Jennifer González-Colón, amends Sections 1061.03 and 1061.09 of the Puerto Rico Internal Revenue Code of 2011, as amended (“PR Code”) to establish the new filing deadlines for Informative Returns of Pass-Through Entities, as well as for Trust Returns. These changes in filing due dates are effective for taxable years beginning after December 31, 2024.
Informative Income Tax Return on Pass-Through Entities
Under PR Code Section 1061.03, every Pass-Through Entity was required to file an annual tax return reporting its gross income, allowable deductions, the names, addresses, and account numbers of the partners, as well as each partner’s share of the entity’s income or loss. Entities filing on a calendar year basis were required to submit their return, Form 480.2EC, no later than March 15 of the following year, while those filing on a fiscal year basis had to do so by the fifteenth (15th) day of the third (3rd) month after the close of their taxable year. In prior years, the filing of Pass-Through Entity returns followed the guidance set forth in Puerto Rico Internal Revenue Circular Letter No. 25-05 that for taxable year 2024, as well as for the taxable years 2021, 2022, and 2023, the filing of the Pass-Through Entity Return was required to be simultaneous with the submission of all corresponding Forms 480.6EC no later than the last day of the third (3rd) month following the close of the taxable year. Consequently, the filing deadline for both the Pass-Through Entity Return and the accompanying Forms 480.6EC (i.e. informative returns to the members) was aligned with the date established in the Code for providing these forms to partners, members, or shareholders, the last day of the third (3rd) month following the close of the taxable year.
Under the amendments introduced by the Act, the filing deadlines for forms 480.2EC and 480.6EC have been unified, and all returns must now be submitted no later than the last day of the third (3rd) month following the close of the entity’s taxable year.
Revocable Trust or Grantor Trust Informative Income Tax Returns
Under PR Code Section 1061.09, Revocable Trusts and Grantor Trusts are required to file Form 480.8F, Revocable Trust or Grantor Trust Informative Income Tax Return. Such return must report on the items of gross income, receipts, disbursements, and any other information in the form and manner prescribed by the Secretary through regulations, circular letters, informational bulletins, or general administrative determinations. The filing due date was no later than the fifteenth (15th) day of the third month following the close of the trust´s taxable year. The revocable trust or grantor trust has until the last day of the third (3rd) month following the close of the taxable year to provide grantors with the electronically filed forms 480.6F, Revocable Trust or Grantor Trust Informative Return.
The amendments introduced by Act modified the filing due date for the Revocable Trust and Grantor Trust Returns, aligning them with the new deadlines applicable to other entities. The annual return must now be filed no later than the last day of the third (3rd) month following the close of the trust´s taxable year, streamlining the compliance process with the filing of the accompanying Forms 480.6F.
In sum, these amendments provide long-awaited certainty by formally incorporating the filing deadlines into the Puerto Rico Internal Revenue Code. This change eliminates the prior uncertainty and annual reliance on circular letters from the Department of Treasury that temporarily extended the due dates to the last day of the applicable filing month.
This document has been prepared for information purposes only and is not intended as and should not be relied upon as legal advice. If you have any questions or comments about the matters discussed in this notice, wish to obtain more information related thereto, or about its possible effect(s) on policy or operational matters, please contact us.