Puerto Rico - Act 60
USVI - EDC Program
Tax Rate on Qualifying Income
Individual Resident Investor: 0% on post-residency interest, dividends, and gains if the application is received by December 31, 2026; 4% if received on or after January 1, 2027 (Act 38-2026)
90% reduction in Virgin Islands income tax on qualifying Virgin Islands-source business income and owner distributions; 2.31% effective corporate rate at 90%
Employee Requirement
None for the Individual Resident Investor decree
10 full-time resident employees; 5 for certain financial and service categories (29 V.I.C. §708(f); verify category)
Minimum Investment
No dollar minimum; a Puerto Rico principal residence must be purchased within 2 years after the decree
$100,000 in an approved business, exclusive of inventory (29 V.I.C. §708(a))
Annual Statutory Costs
$15,000: $10,000 charitable contribution plus $5,000 annual report charge (Code §6020.10(b), (d))
$3,000 scholarship contribution plus an annual compliance fee of $1,500 to $7,500 by category (2019 text), plus employee payroll
Tax System
Puerto Rico Internal Revenue Code. Federal exclusion of Puerto Rico-source income only (IRC §933); U.S.-source income stays taxable by the IRS
IRC mirror code. A bona fide resident reporting all income to the Virgin Islands is excluded from U.S. gross income (IRC §932(c)(4)); the EDC reduction reaches only Virgin Islands-source or effectively connected income (§934(b))
Program Duration
Decree through December 31, 2035 (0% regime) or December 31, 2055 (4% regime)
20 years (St. Thomas / St. John) or 30 years (St. Croix), with possible extensions (29 V.I.C. §713a(b))
Application Deadline
December 31, 2026 (11:59 pm) for the 0% regime
No fixed filing deadline comparable to Act 60's was found in the sources reviewed. Confirm the current application calendar with the Authority.
Best For
Investors whose income is mainly interest, dividends, and capital gains, with no business or employees required
Operating businesses and service or financial firms with Virgin Islands-source income and capacity to hire resident employees