P.R. Laws tit. 13, § 33077
(a) The Secretary may, at his/her judgment and discretion, release a taxpayer from surcharges and interest established in § 33072 of this title as pertains to taxes imposed under §§ 31601 et seq. or §§ 32001 et seq. of this title, and he/she may fix a new date of payment under the following circumstances:
(1) When, within six (6) months of the effectiveness of a new provision of law or a regulation, a taxpayer submits a written consultation to the Secretary concerning a construction of such legal or regulatory provision due to the complexity of the matter involved, and the Secretary takes over ninety (90) days from the date of receipt of such consultation at his/her office to issue his/her answer.
(2) When dealing with new items or taxable items that are new in the market of Puerto Rico, which create a reasonable doubt in terms of their taxable status, classification, or extent pursuant to the laws in effect, insofar as the taxpayer submits to the Secretary the necessary information, not later than ten (10) days before the taxable event, to determine its taxable status, if any.
(3) When the taxpayer files a well grounded, written allegation concerning his/her status as exempt from paying taxes, and the Secretary, by reason of the legal difficulty or complexity, takes more than ninety (90) days from the date of receipt of such consultation in his/her office to issue his/her answer.
(4) When the Secretary clearly and definitely leads a taxpayer to error when the taxpayer submits a written consultation concerning a contentious issue that until that time has not been clarified by any regulations or promulgation by the Secretary. In such case, it shall be the duty of the taxpayer thus affected to prove beyond any reasonable doubt that he/she acted diligently when consulting the Secretary.
History —Jan. 31, 2011, No. 1, § 6030.07, retroactive to Jan. 1, 2011.