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. jurisdiction75% of the island — is covered by OZ designationsDiverse locations — Urban, suburban, and rural optionsExisting 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 services0% tax on dividends — from export services income0% tax on capital gains — (for bona fide residents)15-year decree term
Act 60 Individual Investor:
0% capital gains tax — for new PR residents0% tax on dividends and interestMust become bona fide PR residentMinimum charitable contribution required
Combined OZ + Act 60 Benefits:
| Benefit | Federal OZ | Act 60 | Combined |
|---------|-----------|--------|----------|
| Capital gains deferral | Yes | N/A | Yes |
| Capital gains exclusion (10yr) | Yes | Yes (residents) | Maximum benefit |
| Corporate tax rate | Standard | 4% | 4% |
| Dividend tax | Standard | 0% | 0% |
| Property tax | Standard | Possible exemption | Possible exemption |
Manufacturing in Puerto Rico
Existing Infrastructure
Puerto Rico has a long history of manufacturing:
Pharmaceutical manufacturing — Major hub for global pharmaMedical devices — Significant production capacityElectronics — Circuit board and component manufacturingAerospace — Growing sector with established facilitiesFood processing — Serving both local and export markets
Workforce Advantages
Bilingual workforce — English and SpanishUniversity system — UPR and private universities producing engineers and scientistsTechnical training — Vocational schools and apprenticeship programsU.S. citizens — No work visa requirementsCompetitive wages — Lower than mainland but with U.S. labor protections
Strategic Location
Gateway to the Americas — Between North and South AmericaCaribbean hub — Central to Caribbean trade routesForeign Trade Zones — Multiple FTZs for import/export advantagesPort infrastructure — Major ports in San Juan, Ponce, and MayaguezAir connectivity — Direct flights to major U.S. and international cities
Defense Manufacturing Opportunities
Current Defense Presence
Fort Buchanan — U.S. Army installationRoosevelt Roads — Former naval station with redevelopment potentialCoast Guard — Significant Caribbean operationsNational Guard — Active manufacturing support
Defense Manufacturing Potential
Electronics and sensors — Leveraging existing electronics manufacturing basePharmaceutical and chemical — Defense-grade chemical productionComposite materials — Aerospace and defense applicationsPrecision machining — CNC manufacturing for defense componentsRenewable energy systems — Military microgrids and energy resilience
Federal Contracting Advantages
HUBZone — Many PR locations qualify8(a) eligibility — Significant disadvantaged business populationBuy American compliance — PR is U.S. territorySet-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 yearsAct 60: 4% corporate tax on export manufacturingHUBZone: Access to set-aside contractsWorkforce: Skilled machinists at competitive wagesProjected 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 facilityAct 60: 4% tax rate on products shipped to mainlandCMMC: Secure facility for defense electronicsProjected 10-year tax savings: $2-4 million
Challenges and Considerations
Infrastructure
Power grid reliability (improving but still a concern)Water system capacityBroadband connectivity (improving)Road conditions vary by location
Regulatory Environment
Puerto Rico-specific business regulationsEnvironmental permitting requirementsLabor 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 designInstall backup power generationDevelop comprehensive business continuity plansMaintain adequate insurance coverageDiversify operations across multiple locations
Getting Started
Research OZ locations using Treasury Department maps and PR economic development resourcesEngage with PRIDCO (Puerto Rico Industrial Development Company) for site selectionConsult tax advisors experienced in both OZ and Act 60 incentivesVisit potential sites and meet with local officialsDevelop a business plan incorporating all available incentivesConnect with KDM & Associates for defense contracting integrationStructure 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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Join the KDM Consortium Platform today:
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