Tax Liens in Puerto Rico: Hacienda, CRIM, and Release

Tax liens in Puerto Rico are legal claims the commonwealth places on everything you own when you fall behind on taxes, and they stay attached until you pay in full or the collection period runs out. Two agencies file them: the Puerto Rico Department of the Treasury (Hacienda) for income, sales and use, excise, and withholding taxes, and the Municipal Revenues Collection Center (CRIM) for real and personal property taxes. Once a lien is on record, you cannot sell or refinance the affected property with clear title, and Hacienda can reach your wages and bank accounts directly.

Which Agency Filed the Lien

Hacienda operates under the Puerto Rico Internal Revenue Code of 2011 (Act 1-2011), which gives it authority to assess, demand payment, and file liens against taxpayers who fall behind on income, sales and use, excise, or withholding taxes.¹

CRIM handles everything tied to property taxes. Its authority now sits in the Puerto Rico Municipal Code of 2020 (Act 107-2020), which absorbed the older Municipal Property Tax Act of 1991.² All powers over property tax collection, including preferred liens once held by the Secretary of the Treasury, were transferred to CRIM.³ Knowing which agency issued your lien determines where you file payments, request payment plans, and eventually seek a release.

How the Lien Attaches to Your Property

A lien follows a set sequence. The agency assesses what you owe, sends a formal demand for payment, and, if you don’t pay, files a tax lien certification at the Property Registry where you live or where your real estate is located.⁴

The certification serves as public notice of the government’s claim. It must include the taxpayer’s name and residence, the total amount owed (fines, interest, surcharges, and penalties included), and the serial number of the notice. Once filed, the lien covers all real and personal property belonging to the debtor and stays in place until the full amount is paid or the collection window closes.

For property taxes, CRIM holds what the Municipal Code calls a “preferential tax lien.” It covers the current fiscal year plus the five previous years and takes priority over every other lien on the property, regardless of when those competing liens were filed.⁵

What the Lien Actually Restricts

The most immediate consequence is title. Any title search will show the government’s claim, and buyers, lenders, and title insurers will not close on a property with an active lien. Selling and refinancing are effectively off the table.

Hacienda can also reach specific assets directly, without waiting for a real estate transaction:

Wages and salary. The government can garnish 25% of your wages after mandatory deductions for Social Security, income tax, retirement contributions, and child support. Voluntary payroll deductions such as loan payments or savings have no priority over the garnishment, and it continues until the full amount is paid.⁴
Bank accounts. A levy freezes the balance available at the moment the notice arrives, or the amount owed, whichever is less. Deposits made after that notice are not caught by the same levy, though Hacienda can issue a new one against later balances.
Accounts receivable. A levy on money third parties owe you acts as a continuing preferred levy on those receivables until the debt is fully paid.

How the Debt Grows While You Wait

Unpaid taxes accumulate interest and surcharges from the moment you miss the deadline. For property taxes administered by CRIM, interest runs at 10% per year from the original due date until payment. Surcharges climb with how long payment is overdue:⁶

30 days or less overdue: no surcharge.
31 to 60 days: 5% of the unpaid amount.
61 to 90 days: 10%.
More than 90 days: 15%.

Overdue real property debt also carries an additional flat 10% surcharge under the Municipal Code.⁵ If you fail to file a property tax return at all, a separate penalty of 5% applies for the first 30 days of the omission, with an additional 5% for each subsequent 30-day period.⁶

How Long the Government Has to Collect

Hacienda’s collection clock has two deadlines. After a debt is assessed, the agency has seven years to pursue payment through administrative or court proceedings. Once ten years have passed from the assessment date, the Secretary of the Treasury must remove the debt from the agency’s files and is barred from collecting it, either on its own initiative or at the taxpayer’s request.⁷

The assessment itself must happen within four years of filing a return, or six years if you omitted more than 25% of gross income, sales and use tax, or excise tax.⁸ A full assessment-plus-collection cycle can therefore stretch to 14 years, and longer where underreporting extends the assessment window.

For property taxes under CRIM, personal property tax debt becomes uncollectible after 10 years and real property tax debt after 15 years.

Payment Plans Before Things Get Worse

Hacienda offers structured payment plans that can stop the collection process before seizure. There are two categories: automatic plans for debts of $50,000 or less in principal, and regular plans for larger amounts.

For income tax debts under the automatic plan, the terms scale with the balance:

$10,000 or less: up to 24 months, no down payment, paid by direct bank debit.
$10,001 to $25,000: up to 36 months, with a 10% down payment on the principal.
$25,001 to $50,000: up to 36 months, with a 20% down payment on the principal.

Sales and use tax and withholding tax debts follow tighter schedules with weekly installments through the SURI portal. If your principal exceeds $50,000, you must apply for a regular payment plan and show the Secretary that you cannot pay the full amount immediately. Interest and surcharges keep accruing during any plan, so a longer schedule costs more overall. Applications go through SURI or a regional office using Form 3509 or Form 3510.

Seizure and Public Auction

If the debt is not resolved, both Hacienda and CRIM can seize and sell property. For property tax debts, CRIM issues a written notice of seizure listing the full amount owed. If 30 days pass without payment of the debt plus interest, surcharges, and fees, the property can be sold at public auction.⁹

Before the sale, the auction notice must run at least twice, once per week, in a newspaper of general circulation in Puerto Rico, and edicts must be posted for two weeks in three public places in the municipality where the sale will occur.⁹ The notice must state the date, place, and conditions of the sale. Only the portion of property strictly sufficient to cover the debt needs to be sold.⁵ By the time an auction is scheduled, the original tax will have been inflated by years of 10% annual interest, surcharges, and collection costs.

How to Get a Tax Lien Released

Clearing a lien is a two-step process: the agency issues a cancellation document, and you record it at the Property Registry.

Income Tax Liens Through Hacienda

The Secretary of the Treasury can issue a certificate of release once the full debt (including interest, fines, penalties, and surcharges) has been paid or has become legally unenforceable. The Secretary may also release a lien if the taxpayer posts a bond guaranteeing full payment on terms the Secretary finds acceptable.¹⁰

To request the release, gather proof of payment (Colecturía receipts or digital payment confirmations) matching the exact tax periods and amounts in the original lien notice, and identify the volume and page number where the lien is recorded in the Property Registry so the release targets the correct entry. Filings go through SURI or in person at a regional Colecturía.

Property Tax Liens Through CRIM

For property tax liens, work through the CRIM regional office covering the property’s location. CRIM’s online portal offers account statements and value certifications that help establish the current balance on your property.¹¹ You’ll need a zero balance on the specific property code before requesting formal cancellation.

Precision matters in both cases. Any mismatch between your payment receipts and the amounts on the debt records can delay the process, so verify that every payment covers the original tax plus all accumulated interest, penalties, and surcharges before applying for the release.

Recording the Cancellation at the Property Registry

Approval from the agency is not the final step. You then record the cancellation document, called the Cancelación de Gravamen, at the Property Registry so the public record shows clear title.¹⁰ Until this is done, title searches will still show the lien even though the debt is satisfied. The Property Registry charges filing fees that vary with the type and complexity of the filing, so confirm costs with the relevant registry section before submitting.

Where a Federal Tax Lien Fits In

If the IRS also has a claim against you, both governments can file liens on the same property. Priority follows the federal “first in time, first in right” rule set by the U.S. Supreme Court: a competing lien must be fully perfected (creditor identified, amount fixed, specific property identified) before the federal tax lien arises on its assessment date. Puerto Rico cannot override this by declaring its own liens automatically superior.¹²

There is one carve-out. Real property taxes and special assessments can qualify for superpriority status under federal law, which lets them jump ahead of a federal tax lien regardless of filing order. CRIM’s preferential property tax lien covering the current year plus five prior years may fall under that exception. Hacienda’s income tax liens, by contrast, compete with the IRS on straight timing.

1
Office of Management and Budget of Puerto Rico. Puerto Rico Internal Revenue Code of 2011
2
Government of Puerto Rico. Act 26-2023 – To Amend Section 4.1 of Act 38-2017
3
Municipal Revenue Collection Center (CRIM). Municipal Property Tax Act of 1991
4
Justia. Puerto Rico Code 13 33261 – Tax Lien Certification; Seizure and Sale of Debtor’s Property
5
Municipal Revenue Collection Center. Regulations for the Collection, Seizure and Disposition of Properties
6
Justia. Puerto Rico Code 21 5221 – Interest on Underpayments
7
United States Bankruptcy Court for the District of Puerto Rico. Opinion and Order – Case No. 14-09404
8
Justia. Puerto Rico Code 13 33005 – Period of Limitation on Assessment and Collection
9
Justia. Puerto Rico Code 21 5937 – Auction Notice
10
Justia. Puerto Rico Code 13 33280 – Release of Lien or Discharge of Property
11
Centro de Recaudación de Ingresos Municipales. Centro de Recaudación de Ingresos Municipales
12
Internal Revenue Service. Chief Counsel Advice: Priority of Federal Tax Lien