-
Financial statements audits
Financial statement audits
-
Compliance audits
Compliance audits
-
Compilations and reviews
Compilations and audit
-
Agreed-upon procedures
Agreed-upon procedures
-
Corporate and business tax
Our trusted teams can prepare corporate tax files and ruling requests, support you with deferrals, accounting procedures and legitimate tax benefits.
-
International tax
Our teams have in-depth knowledge of the relationship between domestic and international tax laws.
-
Tax compliance
Business Tax
-
Individual taxes
Individual taxes
-
Estate and succession planning
Estate and succession planning
-
Global mobility services
Through our global organisation of member firms, we support both companies and individuals, providing insightful solutions to minimise the tax burden for both parties.
-
Sales and use tax and indirect taxes
SUT/ VAT & indirect taxes
-
Tax incentives program
Tax incentives program
-
Transfer Pricing Study
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public
-
Business consulting
Our business consulting services can help you improve your operational performance and productivity, adding value throughout your growth life cycle.
-
Forensic and investigative services
At Grant Thornton, we have a wealth of knowledge in forensic services and can support you with issues such as dispute resolution, fraud and insurance claims.
-
Fraud and investigations
The commercial landscape is changing fast. An ever more regulated environment means organizations today must adopt stringent governance and compliance processes. As business has become global, organizations need to adapt to deal with multi-jurisdictional investigations, litigation, and dispute resolution, address the threat of cyber-attack and at the same time protect the organization’s value.
-
Dispute resolutions
Our independent experts are experienced in advising on civil and criminal matters involving contract breaches, partnership disputes, auditor negligence, shareholder disputes and company valuations, disputes for corporates, the public sector and individuals. We act in all forms of dispute resolution, including litigation, arbitration, and mediation.
-
Business risk services
We can help you identify, understand and manage potential risks to safeguard your business and comply with regulatory requirements.
-
Internal audit
We work with our clients to assess their corporate level risk, identify areas of greatest risk and develop appropriate work plans and audit programs to mitigate these risks.
-
Service organization reports
As a service organization, you know how important it is to produce a report for your customers and their auditors that instills confidence and enhances their trust in your services. Grant Thornton Advisory professionals can help you determine which report(s) will satisfy your customers’ needs and provide relevant information to your customers and customers’ auditors that will be a business benefit to you.
-
Transaction advisory services
Transactions are significant events in the life of a business – a successful deal that can have a lasting impact on the future shape of the organizations involved. Because the stakes are high for both buyers and sellers, experience, determination and pragmatism are required to bring deals safely through to conclusion.
-
Mergers and acquisitions
Globalization and company growth ambitions are driving an increase in M&A activity worldwide as businesses look to establish a footprint in countries beyond their own. Even within their own regions, many businesses feel the pressure to acquire in order to establish a strategic presence in new markets, such as those being created by rapid technological innovation.
-
Valuations
We can support you throughout the transaction process – helping achieve the best possible outcome at the point of the transaction and in the longer term.
-
Recovery and reorganization
We provide a wide range of services to recovery and reorganisation professionals, companies and their stakeholders.
Transfer Pricing in Puerto Rico
If the proposed Tax Reform (H.R. 1544) is passed as presented to the Puerto Rico Legislature on April 16, 2018, the 2011 Puerto Rico Internal Revenue Code, as amended (PR Code) will suffer significant changes. The following are among the proposed changes that affect corporations: 1) a reduction in tax rates, 2) various changes to the alternative minimum tax, 3) limitation on certain deductions. We want to highlight one particular proposal, which would have a positive impact on most corporations that have transactions with related entities outside Puerto Rico.
The PR Code establishes a 51% limitation on the amount of deductions that an entity can take for expenses paid to related entities outside PR or on allocations of expenses made to the PR entity. This disallowance has been subject of debate since it was established in 2013. The most renowned public debate on the subject came as a result of the case Wal-Mart Puerto Rico, Inc. V. Juan C. Zaragoza Gómez, Civil No. 3: 15-cv-03018(JAF). However, in this case the Court ruled only on the alternative minimum tax impact related to these expenses. The disallowance of the deductions was not specifically addressed. Subsequently, the PR Treasury Department issued Administrative Determination 16-11, confirming that the disallowance was still in effect.
The proposed tax reform maintains the 51% disallowance as it is now, but with one important exception. The exception provides that an entity that has made a transfer pricing study to support the charges from related entities will not be subject to the 51% disallowance. It also establishes that the rules to be followed for the transfer pricing study will be those presented on Section 482 of the United States Internal Revenue Code of 1986, as amended and its regulations.
An important aspect of this proposal is that unlike most of the proposed changes, which will be effective for 2019, this particular provision will be effective for 2018.
What can you do to be prepared?
First, determine if your company has been affected by the 51% disallowance in prior years’ tax returns. Second, stay tuned to the final language that will be approved by the Legislature (this should be final on or before June 30 unless the project is moved to an extraordinary session in July). Third, you need to start working on a transfer pricing study to cover your intercompany charges for 2018.
Affected companies should prepare a preliminary transfer pricing study before year end so that they can make any necessary adjustments on the intercompany charges and then complete the study with actual yearend information.
We will keep you informed about the status of this legislation. Please contact us to discuss your particular case.
