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Puerto Rico's Opportunity Zones: Manufacturing and Defense Potential

Puerto Rico offers 863 Opportunity Zones combined with Act 60 incentives, creating unmatched tax advantages for manufacturing and defense investment.

KDM & Associates
January 8, 2026
9 min read
Puerto RicoOpportunity ZonesManufacturingDefenseAct 60

Puerto Rico presents a unique proposition for manufacturers and defense contractors: 863 designated Opportunity Zones combined with the island's own Act 60 tax incentives create what may be the most favorable tax environment for manufacturing investment anywhere in the United States. Add in an existing manufacturing infrastructure, skilled bilingual workforce, and strategic Caribbean location, and the case becomes compelling.


Puerto Rico's OZ Advantage


Scale of Opportunity

  • 863 Opportunity Zones — More per capita than any U.S. jurisdiction
  • 75% of the island — is covered by OZ designations
  • Diverse locations — Urban, suburban, and rural options
  • Existing infrastructure — Many OZs include former manufacturing sites

  • Stacking Incentives: OZ + Act 60

    Puerto Rico's Act 60 (formerly Acts 20 and 22) provides additional incentives that stack on top of federal OZ benefits:


    Act 60 Export Services:

  • 4% corporate tax rate — on eligible export services
  • 0% tax on dividends — from export services income
  • 0% tax on capital gains — (for bona fide residents)
  • 15-year decree term

  • Act 60 Individual Investor:

  • 0% capital gains tax — for new PR residents
  • 0% tax on dividends and interest
  • Must become bona fide PR resident
  • Minimum charitable contribution required

  • Combined OZ + Act 60 Benefits:

    BenefitFederal OZAct 60Combined

    |---------|-----------|--------|----------|

    Capital gains deferralYesN/AYesCapital gains exclusion (10yr)YesYes (residents)Maximum benefitCorporate tax rateStandard4%4%Dividend taxStandard0%0%Property taxStandardPossible exemptionPossible exemption

    Manufacturing in Puerto Rico


    Existing Infrastructure

    Puerto Rico has a long history of manufacturing:

  • Pharmaceutical manufacturing — Major hub for global pharma
  • Medical devices — Significant production capacity
  • Electronics — Circuit board and component manufacturing
  • Aerospace — Growing sector with established facilities
  • Food processing — Serving both local and export markets

  • Workforce Advantages

  • Bilingual workforce — English and Spanish
  • University system — UPR and private universities producing engineers and scientists
  • Technical training — Vocational schools and apprenticeship programs
  • U.S. citizens — No work visa requirements
  • Competitive wages — Lower than mainland but with U.S. labor protections

  • Strategic Location

  • Gateway to the Americas — Between North and South America
  • Caribbean hub — Central to Caribbean trade routes
  • Foreign Trade Zones — Multiple FTZs for import/export advantages
  • Port infrastructure — Major ports in San Juan, Ponce, and Mayaguez
  • Air connectivity — Direct flights to major U.S. and international cities

  • Defense Manufacturing Opportunities


    Current Defense Presence

  • Fort Buchanan — U.S. Army installation
  • Roosevelt Roads — Former naval station with redevelopment potential
  • Coast Guard — Significant Caribbean operations
  • National Guard — Active manufacturing support

  • Defense Manufacturing Potential

  • Electronics and sensors — Leveraging existing electronics manufacturing base
  • Pharmaceutical and chemical — Defense-grade chemical production
  • Composite materials — Aerospace and defense applications
  • Precision machining — CNC manufacturing for defense components
  • Renewable energy systems — Military microgrids and energy resilience

  • Federal Contracting Advantages

  • HUBZone — Many PR locations qualify
  • 8(a) eligibility — Significant disadvantaged business population
  • Buy American compliance — PR is U.S. territory
  • Set-aside opportunities — Full access to federal small business programs

  • Investment Case Studies


    Case 1: Precision Manufacturing Facility

    Investment: $5 million in OZ-designated industrial park

    Operations: CNC machining for aerospace and defense

    Benefits:

  • OZ: Zero tax on facility appreciation after 10 years
  • Act 60: 4% corporate tax on export manufacturing
  • HUBZone: Access to set-aside contracts
  • Workforce: Skilled machinists at competitive wages
  • Projected 10-year tax savings: $1.5-3 million

  • Case 2: Electronics Assembly Operation

    Investment: $8 million in former pharmaceutical facility (OZ)

    Operations: Printed circuit board assembly and testing

    Benefits:

  • OZ: Substantial improvement of existing facility
  • Act 60: 4% tax rate on products shipped to mainland
  • CMMC: Secure facility for defense electronics
  • Projected 10-year tax savings: $2-4 million

  • Challenges and Considerations


    Infrastructure

  • Power grid reliability (improving but still a concern)
  • Water system capacity
  • Broadband connectivity (improving)
  • Road conditions vary by location

  • Regulatory Environment

  • Puerto Rico-specific business regulations
  • Environmental permitting requirements
  • Labor laws (U.S. federal + PR-specific)
  • Tax compliance complexity (dual jurisdiction)

  • Natural Disaster Risk

  • Hurricane exposure (mitigation planning essential)
  • Earthquake risk (southern coast)
  • Insurance costs (higher than mainland)
  • Business continuity planning critical

  • Mitigation Strategies

  • Invest in resilient facility design
  • Install backup power generation
  • Develop comprehensive business continuity plans
  • Maintain adequate insurance coverage
  • Diversify operations across multiple locations

  • Getting Started


  • Research OZ locations using Treasury Department maps and PR economic development resources
  • Engage with PRIDCO (Puerto Rico Industrial Development Company) for site selection
  • Consult tax advisors experienced in both OZ and Act 60 incentives
  • Visit potential sites and meet with local officials
  • Develop a business plan incorporating all available incentives
  • Connect with KDM & Associates for defense contracting integration
  • Structure investment through a Qualified Opportunity Fund

  • Conclusion


    Puerto Rico's combination of Opportunity Zones, Act 60 incentives, manufacturing infrastructure, and strategic location creates an unmatched environment for defense manufacturing investment. For investors and manufacturers willing to navigate the complexity, the potential returns—both financial and strategic—are exceptional.



    Ready to Take the Next Step?

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