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PALMAS

                                                                                                                                                   DEL MAR
              OFFSHORE BANKING ACT

              AN INTERNATIONAL BANKING PLATFORM TO EXPORT FINANCIAL SERVICES TO FOREIGN MARKETS





              The International Financial Center Regulatory Act   • Trust services                                    TAX BENEFITS UNDER ACT NO. 273:
              (Act 273) seeks to expand the potential market of   • Securities brokerage                              • IFEs will enjoy a 4% flat income tax rate on
              the International Financial Center of Puerto Rico.
                                                                  • Clearinghouse services                              their income
              The benefits of an international financial center in                                                    • Distributions from earnings and profits derived
              Puerto Rico are the expansion of the service sector,   • Asset management                                 from IFEs:
              as well as the direct and indirect creation of employ-  • Other financial services
              ment and growth in the economic activity. Puerto    IFEs are generally not permitted to do transactions   • Taxed at 6% for shareholders that are Puerto
              Rico offers many favorable conditions to perform    with local Puerto Rico counterparts, except in        Rico residents
              international financial transactions, such as political   certain cases such as these:                  • 100% exemption from Puerto Rico taxes on
              stability, the soundness of its banking system, the                                                       such dividends
              close economic relationship with the United States,   • Certain transactions involving the Government   • Municipalities in Puerto Rico may levy a gross
              the high degree of professionalism, bilingualism and   Development Bank and the Economic Develop-         receipts tax of up to 1.5% for financial services
              technical capacity of its human resources, a unified   ment Bank of Puerto Rico
              market and monetary system, its privileged geo-     • Certain transactions and activities involving secu-  • IFEs will be 100% exempt from all property taxes
              graphical position and a properly developed com-      rities issued by the Government of Puerto Rico    • A 15 year tax decree, renewable for two (2)
              munications network.                                • Participation in local loan syndications originated   additional 15 year periods

              To meet the purposes hereinafter mentioned, the       by a local bank
              law provides for the organization of International   • Purchasing of substandard or non-performing
              Financial Entities (IFE). An IFE is a Puerto Rico entity   loans from Puerto Rico entities
              engaged in traditional banking or financial services
              for non-Puerto Rican clients. IFEs are under the
              supervision of the Office of the Commissioner of
              Financial Institutions.



              ELIGIBLE BANKING ACTIVITIES UNDER
              ACT 273:
              • Accepting deposits
              • Borrowing money

              • Lending
              • Letters of credit
              • Refinancing

              • Foreign currency exchange
              • Underwriting
              • Trade financing



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