The billPuerto Rico today taxes dividends paid to nonresident foreign individuals at 15% and to foreign corporations not engaged in a trade or business on the island at 10% ^[1][2]. House Bill 952, authored by House Speaker Carlos "Johnny" Mendez Nunez and other legislators, would let qualifying residents of Spain and eligible Spanish corporations be taxed under the U.S.-Spain tax treaty instead of those standard local rates ^[3]. Under the treaty's 2013 protocol, dividends generally carry a 15% rate, 5% when the recipient holds at least 10% of voting shares, and 0% for a company owning more than 80% for at least 12 months ^[4][5][6]. Read against Puerto Rico's own rates, the bill's real beneficiaries are corporate shareholders - precisely the profile of a company establishing operations and capital on the island. Individual Spanish investors would mostly see the same 15% they already pay. The Board's objectionThe Financial Oversight and Management Board warned this week that the bill, as drafted, violates PROMESA Section 204(c), which requires new laws to stay consistent with the certified fiscal plan ^[7]. The Board cites a legislative analysis estimating the cost at $383,100 in lost revenue for every 1% of qualifying dividends, and notes the bill includes no mechanism to replace it ^[8][9]. The arithmetic deserves honesty in both directions. Scale that per-point estimate to the full dividend base and the implied ceiling is roughly $38 million a year - a modest sum against the capital the bill courts, but a real one for a fiscal plan running on narrow margins. The Board's objection is less about hostility to foreign investment than about a missing half of the ledger: the cost is countable today, while the investment it might attract has never been estimated publicly. The part that outlives the billOnly federal negotiators can close the underlying gap - the U.S.-Spain treaty does not expressly include Puerto Rico ^[10], and Gov. Jenniffer Gonzalez Colon already asked the U.S. Treasury to address the double taxation during a November 2025 trade mission to Spain ^[11]. That is the durable fix, and it does not cost the fiscal plan a cent. The actionable path is therefore two-track: keep the treaty petition moving in Washington, and if lawmakers want the local workaround, bring it to the table with an offset attached - as the Board itself recommends, folded into a broader tax reform ^[12]. Puerto Rico has spent a decade proving incentives can move capital. The next step is proving they can be engineered to survive fiscal discipline.