On May 28, 2026, Law 526 of 2026 was enacted and published, introducing rules of economic substance for certain entities incorporated or domiciled in Panama that obtain passive income from foreign sources.
The regime will begin to apply from the 2027 fiscal year. Although the regulations are still pending, there is a window to diagnose structures, document the actual operation and decide on adjustments in time.
5 key points
The rule maintains as point the principle of territoriality, but creates a special review for passive income from foreign sources.
covered rents These include dividends, interest, royalties, capital gains, income from real estate capital, and other income from movable capital.
The entity must demonstrate economic substance: Effective management and direction, human resources, facilities, assets and adequate operating expenses in Panama.
When the requirements are not met or documented, the foreign passive income It could be subject to a single and final rate of 15% on the net taxable income.
The entry into force in 2027 allows anticipate the impactReview existing vehicles and strengthen evidence before the first applicable period.
What do we recommend?
Don't wait for regulations to make the initial diagnosis.
Check who makes decisions, where There are the assets, how Expenses are covered and the structure maintains fiscal and corporate consistency.
