Puerto Rico has reportedly introduced new transfer pricing study submission rules in relation to the general 51% disallowance of deductions with respect to cross-border expenses incurred with related persons not engaged in trade or business in Puerto Rico. Previously, taxpayers have been allowed to submit a request to the tax authority for full or partial relief from the general disallowance. With effect for fiscal years ending on or after 31 December 2019, relief from the disallowance is provided if the taxpayer submits a transfer pricing study with their tax return. In general, studies prepared in accordance with U.S. transfer pricing...