March 12, 2021
Puerto Rico's Treasury Department extends the time for pass-through entities to file their returns to April 15
The Puerto Rico Treasury Department (PRTD) has extended (Circular Letter (CL) 21-07) the due date from March 15, 2021 to April 15, 2021 for pass-through entities that are partnerships, special partnerships or corporations of individuals to file their calendar tax year 2020 income tax returns.
Generally, pass-through entities must file the Return for Pass-through Entities no later than the 15th day of the third month following the close of the tax year (March 15 in the case of calendar-year-end taxpayers). Additionally, they must file Form 480.6EC through the Unified Internal Revenue System (SURI by its Spanish acronym) and send it to the partners no later than the last day of the third month following the close of the tax year.
CL 21-07 is extending the time to file the return and the corresponding partners' Form 480.6EC to April 15, 2021. CL 21-07 also contains step-by-step instructions for filing through SURI. The link for filing the return and Form 480.6EC will be available in SURI beginning March 18, 2021. If an entity needs an extension of time to file, the entity may submit Form SC 2644 to request an automatic extension of time through SURI.
The April 15 extended due date under CL 21-07 is only available to pass-through entities with tax years ended December 31, 2020. CL 21-07 does not mention other pass-through entities, such as grantor trusts and limited liability companies that are subject to taxation as partnerships. The PRTD is expected to issue additional guidance and clarification, especially given that the income tax return must be filed electronically through SURI and a link will not be available until March 18. CL 21-07 also does not reference the combined tax form (Form 480.1(SC)), which is a form for partnerships with various intervening tiers of entities. This form, however, is due when the partnership return is filed, which would mean Form 480.1(SC) would also be subject to the extended April 15 due date.