P.R. Laws tit. 13, § 33207
(a) Power.— The Secretary or his/her authorized representative is hereby empowered to enter into written agreements with any person concerning the liability of such person, or of the person or estate on behalf of which he/she is acting, related to any taxes imposed by this Code for any taxable period. Provided, that in a final agreement, the Secretary shall not:
(1) Accept, after June 30, 2016, payment of future taxes that are not owed by the taxpayer at the time of the execution of the final agreement;
(2) grant or apply to a transaction covered by the final agreement preferential rates or lower rates than those established by this Code or in any special law applicable thereto;
(3) grant or apply deductions or tax credits that are not allowed under this Code or any applicable special law;
(4) classify or apply as overpayment an amount other than previously paid taxes;
(5) extend limitation periods, except as allowed in this Code;
(6) cancel interests or surcharges, except as allowed in this Code;
(7) modify the basis or the amount of the gain on the sale of assets, in a manner that is contrary to the provisions of this Code;
(8) exempt from the requirement of filing returns, unless the return is part of or accompanies the final agreement; or
(9) execute agreements regarding matters or issues over which he/she is not expressly authorized to exercise discretion.
(b) Purpose.— Such agreement, once executed, shall be final and conclusive, and except when proven that there was fraud or deceit, or misrepresentation of a pertinent fact:
(1) The case shall not be reopened concerning the terms agreed upon, nor shall the agreement be modified by any official, employee, or agent of the Government of Puerto Rico, and
(2) Such agreement, or any determination, assessment, charge, payment, reduction, refund, or credit made thereunder shall not be nullified, modified, rendered ineffective, or overlooked in any lawsuit, action, or proceeding.
(c) Penalties.— The penalties for violations regarding final agreements are set forth in § 6030.[sic] of this title.
History —Jan. 31, 2011, No. 1, § 6051.07, retroactive to Jan. 1, 2011; Sept. 30, 2015, No. 159, § 34.