Waves of people are moving to Puerto Rico, including investors, lawyers, hedge funders, and more. Given the astounding tax benefits, many are doing it with good reason. The crypto community may be the biggest wave of all, as the alluring press coverage keeps noting.
For all clients who use a multiple corporation set up, they are aware that they must submit invoices for services performed. The services must be actually performed and at an arm’s length pricing. The contract between the companies must be in writing and should also be approved within the minutes of the company paying for such services. Further, if questioned the client must be able to establish the essentials of an arm’s length agreement. Yet notwithstanding specific direction on how to determine an arm’s length price, having and following a written agreement, some companies do NOT follow the basic requirements to have this type of strategy successfully implemented.