Puerto Rico's Department of the Treasury has launched a Public Consultation on the Implementation of the Pillar Two GloBE Rules in Puerto Rico. The consultation covers general policy considerations and general legal considerations. As noted in the consultation document, the Department of the Treasury is focused on inbound investments at this stage and is not considering the implementation of the Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) at this moment. The effect of this policy decision is the following: MNE Groups headquartered in Puerto Rico will not be required to apply the IIR and therefore, could be potentially...