Tax Planning · Territorial System · Panama

Panama tax planning —
territorial advantages, done legally

Legitimate planning on Panama's territorial tax system: 25% only on Panama-source income, treaty-backed fiscal residency, transfer pricing compliance — and the new economic substance rules (Law 526 of 2026) most advisors haven't read yet.

Why Góndola & Góndola
  • Territorial system: foreign-source income generally untaxed
  • Law 526 of 2026 substance review — before fiscal year 2027
  • Transfer pricing and Form 930 compliance
  • Fiscal residency certificates and treaty relief
  • Ex-DGI insight into how the authority audits
  • Coordination with your home-country advisors
Our Expertise

Why Góndola & Góndola

Panama's territorial system taxes Panama-source income (corporate rate 25%) and generally leaves foreign-source income outside the net. Used with substance and proper home-country reporting, it remains one of the world's cleanest planning platforms.

The 2026 economic substance law changed the rules for multinational groups: foreign passive income now demands demonstrable substance in Panama — people, decisions and spending — or faces a flat 15% tax. Our founding attorney's DGI background means we plan with the auditor's eyes.

Ex-DGI Official

Deep insight into Panama's tax authority processes.

Cornell University MPA

Master in Public Administration — law, economics and policy.

Direct partner access

You always deal directly with the attorney handling your case.

Panama Bar No. 17,005

Licensed attorney in the Republic of Panama.

25%
Corporate rate (Panama-source)
15%
Law 526 rate without substance
930
Transfer pricing return
2027
Substance rules take effect

“Panama tax planning is not a loophole strategy — it is the legitimate use of a transparent territorial system, backed by real substance.”

— Lic. José Manuel Góndola Escudero · Panama Bar No. 17,005
The Guide

What changed with Law 526 of 2026.

Law 526 of 28 May 2026 added economic substance rules to the Fiscal Code for Panamanian entities of multinational groups earning foreign passive income: dividends, interest, royalties, capital gains, foreign real-estate income and other mobile income. From fiscal year 2027, those entities must report that income annually and demonstrate adequate substance in Panama — qualified people and premises, strategic decisions and risks, and operating spend. Entities that fail (or misreport) pay a flat, definitive 15% on that net income.

  • ✓Pure holding companies and passive real-estate holders face a lighter test — people and premises plus reporting.
  • ✓Outsourcing the substance functions is allowed only within Panama, with documented oversight — a service we provide with our sister accounting firm.
  • ✓Regulated financial entities and merchant marine companies have specific carve-outs; preferential regimes (like SEM) still report.
  • ✓The same law tightened Panama's permanent establishment definition — relevant to groups with people or projects in Panama.

If your structure was designed before 2026, the question is no longer “is it territorial?” but “can it prove substance?”. We review structures against the law as written — our team read all of it — and fix what needs fixing before the first affected tax return.

Services

What we handle.

Structure Review

Your Panama entities mapped against territoriality, substance and treaty rules.

Law 526 Substance Planning

People, premises, decisions and spend — designed and documented in Panama.

Transfer Pricing & Form 930

Documentation and filings for related-party transactions.

Fiscal Residency

Residency certificates and treaty positions that hold up.

DGI Defense

Audits, assessments and appeals before the tax authority and the courts.

Cross-Border Coordination

CRS/FATCA-aware planning with your home-country advisors.

Process

How we work.

01

Map the structure

Entities, income flows and where each dollar is actually earned.

02

Apply the rules

Territoriality, Law 526 substance, transfer pricing and treaties — as written.

03

Fix and document

Substance, agreements and filings put in place before the authority asks.

04

Defend if needed

If the DGI questions the structure, we defend it — we built it to be defensible.

FAQ

Frequently asked questions.

How does Panama's territorial tax system work?

Panama taxes income produced within Panama; foreign-source income is generally outside the income tax. The corporate rate on Panama-source taxable income is 25%. That territorial principle is the foundation of legitimate Panama structures.

Did the 2026 economic substance law change the game?

It changed it for multinational groups: Law 526 of 2026 (effective fiscal year 2027) requires Panamanian entities of multinational groups earning foreign passive income — dividends, interest, royalties, capital gains, real-estate and other mobile income — to demonstrate real substance in Panama, or that income is taxed at a flat 15%. Structures designed before 2026 should be reviewed now.

What is Form 930 and who files it?

It is Panama's transfer pricing information return for taxpayers with related-party transactions subject to the regime. Transfer pricing documentation and the 930 filing are core compliance for groups operating through Panama — see our transfer pricing practice.

Can I get a Panama fiscal residency certificate?

Yes, qualifying individuals and companies can obtain fiscal residency certificates from the tax authority, which matter for treaty relief. Panama maintains a network of double taxation treaties; whether you qualify depends on your real ties to Panama.

Is Panama tax planning legal for US or EU taxpayers?

Structuring through Panama is legal when it is substance-backed and properly reported at home — CRS and FATCA mean opacity is not a strategy. We design structures that work because they are real, and we coordinate with your home-country advisors.

Start Here

Is your Panama structure ready
for the substance era?

Confidential consultation in English. We review your structure against the current rules — territoriality, Law 526 and transfer pricing — and quote in writing.