Archivo de Iurispa · corte técnico 2026-09-12
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Executive Decree 32 of 2 September 2026 implements Panama's economic substance law. What it presumes satisfied for a pure holding company, what conduct forfeits the territorial treatment, and why Panama's outsourcing rule departs from the British Virgin Islands and Cayman models it otherwise follows.
The Common Reporting Standard requires Panamanian financial institutions to identify the tax residence of their account holders and report certain data to the authorities of the relevant country. This guide explains what is reported, how self-certification works, why residency-by-investment programmes receive enhanced treatment, and which expectations are worth discarding before opening an account.
People planning to move their tax residency to Panama tend to focus on the destination requirements and discover late that their home country has an invoice waiting for the moment of departure. Exit tax charges gains that have not yet been realised, through a legal fiction. This guide explains how it works, what these regimes share, and why choosing the right destination does not remove it.
Every European client eventually asks, and the question deserves a straight answer. Panama sits in Annex I of the EU list of non-cooperative jurisdictions for tax purposes. This guide explains what that list is, which defensive measures follow from it, how they affect an individual relocating their residence, and the important things it does not mean.
A business owner or executive who travels most of the year cannot meet the 183-day test, however genuinely Panama is their base. Panamanian law provides a second route — the permanent home — but the administration applies it demandingly. This guide does the arithmetic, explains what the DGI really requires when the days are missing, and how to build a file that holds.
A double taxation treaty decides which country taxes each type of income and, when two States both claim the same person as a resident, which of them prevails. Panama has seventeen in force. This guide lists them, explains the Article 4 tie-breaker, and clarifies what happens when there is no treaty — the position most people moving to Panama actually find themselves in.
The territoriality principle in Article 694 of the Fiscal Code is why many foreigners look at Panama in the first place. It is also the concept most often misread. This guide explains what counts as Panama-source income and what does not, where the doubtful cases sit, what formal obligations survive even without tax, and why territoriality does not resolve your position at home.
Moving first to a treaty country and then to the final destination is a widely circulated technique in tax mobility forums and blogs. It is also a figure catalogued in the literature on improper use of treaties, and since the multilateral instrument came into force administrations have a specific tool to deny its benefits. This guide explains when such a structure holds, when it does not, and what separates it from a legitimate relocation.
The most common calendar mistake is assuming the tax residency certificate is obtained whenever you decide to obtain it. It does not work that way: it evidences a factual situation that must already exist, it requires a chain of prior steps, and it takes months to resolve. This guide sets out that chain, gives the timeline for each link, and explains when you can realistically hold the document.
Panama's property tax (impuesto de inmueble, IBI) applies to land and to permanent improvements built on it, valued and exempted under different rules. This guide explains how improvements are valued, what happened to the traditional exemptions after the Law 66 of 2017 reform, and how the current Patrimonio Familiar Tributario (PFT) and Vivienda Principal (VP) benefits work for homeowners.
A guide to Panama's special regimes with tax and zoning benefits: Multinational Enterprise Headquarters (SEM), EMMA, the Panama-Pacifico Special Economic Area, the Colon Free Zone, City of Knowledge, free zones and the tourism regime. Legal basis, concrete incentives and the governing authority for each.
The NT (Número Tributario) is the tax identifier the DGI assigns to foreigners without a Panamanian ID who have fiscal obligations in the country: who needs it, the documents each category requires, and the online procedure through e-Tax 2.0.
What economic substance is and how Panama regulates it under Law 526 of 2026: which entities it covers, which passive income it reaches, the requirements a qualified entity must meet, and the consequence of noncompliance.
What tax residency in Panama is, how to obtain the DGI certificate, how it differs from immigration residency, and why the territorial tax system — which does not tax foreign-source income — attracts investors and nomads worldwide.
Law 189 of 2020 created a special Income Tax regime for micro, small and medium-sized enterprises and for individuals registered as entrepreneurs with AMPYME, with reduced progressive rates compared to the general regime. Eligibility requirements and rate tables in force since fiscal period 2020.
In Panama, RUC and NT are often used almost interchangeably, but they are not the same thing: how each tax identifier is assigned depending on whether you are a national, a foreigner, a local company, or a foreign one.
The NT (Número Tributario), Panama's tax ID for foreigners: who needs it, the documents required by category (professionals, real estate buyers, shareholders), and the step-by-step process through the e-Tax 2.0 portal.
The RUC (Registro Único de Contribuyentes) is Panama's tax identification number for individuals, legal entities, and real estate (fincas). The five taxpayer categories, the specific documents the DGI requires for each, and how to complete the fully online registration through e-Tax 2.0.
How to update your RUC (Taxpayer Registry) data on the DGI's e-Tax 2.0 portal, section by section: identification, tax address, tax obligations and linked third parties. Avoid fines for outdated or incorrect information.
Resolution No. 201-4037 of 2018 adopts the list of participating jurisdictions of the Common Reporting Standard (CRS) for the automatic exchange of financial information, pursuant to Executive Decree 124 of 2017 and Law 51 of 2016.
Executive Decree 122 of 2018 adopts the list of 'Reportable Jurisdictions' within the framework of Law 51 of 2016 for the automatic exchange of financial information for tax purposes (CRS).
HISTORICAL ARCHIVE (2018): the European Union's first list of non-cooperative tax jurisdictions included Panama in the wake of the Paradise Papers scandal. The transparency, exchange-of-information and fair-competition criteria the EU applied to draw up that list, and the sanctions it envisaged for the jurisdictions included.
HISTORICAL ARCHIVE (2018): translation of the questions-and-answers fact sheet (Memo 17/5122) with which the European Commission explained the methodology, criteria and sanctions of its first list of non-cooperative tax jurisdictions, on which Panama was included following the Paradise Papers scandal.