Earlier in the month of September, a panel of representatives from the Puerto Rico Treasury Department (PRTD) at the Puerto Rico CPA State Society's Annual Convention discussed their plan to launch Puerto Rico's new electronic internal revenue unified system, SURI by its Spanish short name, on November 1, 2016, for sales and use tax (SUT) purposes. The PRTD has announced in previous official guidance that SURI will be the new system that the PRTD will use to administer the tax system and that it will implement SURI in phases. The PRTD commented during the panel that merchants should be expecting official administrative guidance on these plans to be issued soon.

Expectations once SURI goes live

The PRTD indicated that merchants currently registered under the SUT provisions will not have to re-register, but they will be required to update their information from October 15 to October 31, 2016. SURI may, however, require merchants to provide additional information. The PRTD commented that the merchant registration number is expected to remain the same. The PRTD will issue a notice to merchants to alert them that they need to access SURI to update their accounts accordingly.

The migration from the current electronic filing system, PICO, to SURI will take place from October 28 to October 30, 2016, during which PICO will not be available. It is expected that merchants will no longer be able to use PICO after October 31, 2016.

Beginning November 1, 2016, it appears that merchants will be able to print their Merchant Certificates directly from SURI. PRTD representatives noted that, under the new system, the certificates will have a new look, with a barcode for security and identification purposes.

Additionally, merchants will be required to file their Importation Declarations through SURI beginning November 1, 2016. Similarly, SURI will have to be used to file the Monthly SUT Returns by November 10 and 20, 2016, as applicable.

Implications

Merchants should be on the lookout for official guidance and communications from the PRTD to validate and confirm its plans on the transition rules from PICO to SURI, particularly as related to the planned effective date and the very short window that will be left for merchants to be ready for the new system.

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