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Healthcare Services (Exports)
Tax incentive for healthcare services provided to patients outside Puerto Rico, offering a 4% corporate tax rate on export healthcare services.
11 min
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Section Code:
2031.01(A)-1 (a)-15
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Purpose:
Exports — 2031.01(A)-1 (a)-15
Overview
The Healthcare Services export incentive under Section 2031.01(A)-1(a)-15 of Act 60-2019, as amended, provides preferential tax treatment for healthcare service providers that serve patients located outside Puerto Rico. This designation supports healthcare services delivered to external patients.
Qualifying businesses pay a fixed four percent (4%) corporate income tax rate on income derived from healthcare services provided to patients outside Puerto Rico. The program may attract telemedicine providers, remote healthcare services, healthcare analytics firms, and other healthcare service models that can serve external patients from Puerto Rico operations.
The key distinction of this designation is its focus on healthcare services provided to patients outside Puerto Rico rather than medical tourism (patients traveling to Puerto Rico) or healthcare infrastructure serving local residents. This may include telemedicine, remote patient monitoring, healthcare data services, or other models.
Puerto Rico's healthcare professionals and infrastructure can support certain healthcare service export models. The incentive enhances competitiveness for innovative healthcare services serving external markets.
Key Benefits
Corporate Income Tax Rate
Healthcare service providers approved under this designation pay a fixed four percent (4%) tax rate on income from qualifying healthcare services to external patients. This rate applies for the decree term of fifteen (15) to twenty (20) years.
Compared to standard Puerto Rico rates of thirty-seven and a half percent (37.5%), savings exceed ninety percent (90%).
Dividend Tax Treatment
Dividends distributed from decree income to shareholders outside Puerto Rico face zero percent (0%) withholding.
Property Tax Exemptions
Healthcare service providers receive exemptions from property taxes on facilities, medical equipment, and technology infrastructure.
Municipal Tax Exemptions
Decree holders are exempt from municipal license taxes on qualifying healthcare services revenues.
Healthcare Professional Access
Providers benefit from Puerto Rico's healthcare professionals who can deliver remote or technology-enabled healthcare services.
Requirements & Obligations
Business Structure and Registration
Applicants must establish a Puerto Rico legal entity to conduct healthcare services and hold the decree. The entity must register with Puerto Rico authorities and obtain necessary healthcare licenses.
Export Revenue Threshold
At least eighty percent (80%) of gross income must derive from healthcare services provided to patients outside Puerto Rico. Services to Puerto Rico patients do not qualify. Detailed patient and service records are required.
Healthcare Services Definition
Services must constitute qualifying healthcare services that can be provided to external patients. This may include telemedicine, remote patient monitoring, healthcare analytics, medical consultation services, or other healthcare services deliverable to external patients. Services must comply with applicable healthcare regulations.
Healthcare Licensing and Compliance
Healthcare services require appropriate licenses and regulatory compliance. Medical professionals must hold valid licenses. Telemedicine and remote healthcare services must comply with regulations in both Puerto Rico and patient jurisdictions.
Service Delivery from Puerto Rico
Healthcare services must be substantially delivered from Puerto Rico by Puerto Rico-based healthcare professionals or staff. Technology platforms and operations must be based in Puerto Rico.
Employment Requirements
Healthcare service providers must hire at least one (1) full-time Puerto Rico resident employee within six (6) months of decree issuance. Healthcare professionals, technical staff, and support personnel count toward requirements.
Physical Presence
The business must maintain facilities in Puerto Rico where healthcare services are delivered or managed. Business records must be kept in Puerto Rico.
Compliance and Reporting
Annual compliance reports must document employment, revenue sources, patient locations, and healthcare licensing status. Records must demonstrate healthcare services to external patients from Puerto Rico operations.
How to Apply
The application process for Healthcare Services export incentives typically requires four (4) to eight (8) months from planning to decree issuance, depending on healthcare licensing requirements.
The process begins with assessing whether the healthcare service model qualifies. Providers should confirm that services can be delivered to external patients, that at least eighty percent (80%) of revenue comes from non-Puerto Rico patients, and that healthcare licensing can be obtained. Consultation with healthcare regulatory and tax advisors is essential.
During planning, providers establish Puerto Rico legal entities, address healthcare licensing, and plan service delivery infrastructure. Licensing requirements depend on specific healthcare services offered.
The formal application is submitted to PRIDCO and includes healthcare service descriptions, service delivery model, patient market analysis, licensing plans, financial projections, and employment plans. Documentation of healthcare credentials should be included.
PRIDCO reviews the application over approximately sixty (60) to ninety (90) days. Staff may request additional information about healthcare services, licensing, or patient service models.
Upon approval, the decree is issued specifying terms and obligations. After issuance, the provider must establish operations, obtain healthcare licensing, and begin service delivery.
This information is educational and should not be considered legal or tax advice. Applicants should consult with qualified legal and tax professionals familiar with Puerto Rico incentive programs before making any business decisions or submitting applications.
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