On January 31, 2024, Hacienda, (the Puerto Rico Department of the Treasury) issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the 2024 limits for Puerto Rico-qualified retirement plans according to Section 1081.01(h) of the Puerto Rico Internal Revenue Code of 2011, as amended.
Following are the applicable 2024 limits for qualified defined contribution retirement plans in Puerto Rico:
Plan Limits |
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| RETIREMENT & SOCIAL SECURITY | US 2024 Limit | PR 2024 Limit | US 2023 Limit | PR 2023 Limit |
| Defined Contribution Plans-Dual Qualified Plans- (see note) | $23,000 | $20,000 | $22,500 | $20,000 |
| Defined Contribution Plans-Puerto Rico Only | $15,000 | $15,000 | ||
| Catch-Up Contributions | $7,500 | $1,500 | $7,500 | $1,500 |
| P.R. Federal Government Employee Catch-Up | $7,500 | $7,500 | ||
| P.R. 1081.01(a) Plan-Voluntary After Tax Cont. | 10% of aggregate compensation for all participation years | 10% of aggregate compensation for all participation years | ||
| Section 415 – Defined Contribution Plan Maximum Annual Contributions without Catch-Up | $69,000 | $69,000 | $66,000 | $66,000 |
| Section 415 – Defined Benefit Plan Maximum Annual Benefit | $275,000 | $275,000 | $265,000 | $265,000 |
| Section 414(q)(1)(B) – Highly Compensated Employee (HCE) – Minimum Compensation listed represents the lookback amount that will be used in the subsequent year. 2024 HCEs made $150,000 in 2023 | $155,000 | $155,000 | $150,000 | $150,000 |
| Section 401(a)(17) – Maximum Includible Annual Compensation | $345,000 | $345,000 | $330,000 | $330,000 |
The IRS limit for elective deferrals applicable to participants in a dual-qualified plan or to federal government employees is $22,500. However, Section 1081.01(d)(7)(iii) of the PR Code limits the elective deferral limits of Puerto Rico participants in a dual-qualified plan to $20,000. Contributions exceeding the $20,000 limit established by the PR Code will be taxable. Consequently, Puerto Rico employees who participate in a dual-qualified plan cannot make elective deferrals over $20,000, even if the IRS limit is $22,500.
