New Economic Substance Rules in Panama: Could your structure fall within the scope of the new regime?

Law 526 of 2026 introduces economic substance requirements and a 15% tax on certain foreign-source passive income earned by specific Panamanian entities.

This new framework does not automatically apply to all entities incorporated or domiciled in Panama. Its scope will depend on factors such as membership in a multinational group, the existence of foreign-source passive income, the tax residence of entities in different jurisdictions, and any exclusions or special regimes to be defined by the pending regulations.

In this video, we summarize the main aspects companies should consider ahead of Fiscal Year 2027.

The forthcoming regulations will be decisive in defining the practical scope of the regime, the applicable reporting obligations, and the criteria to be adopted by the competent authorities.

https://video.wixstatic.com/video/2ebe4f_55b6772be93144809ae39370491c13b7/1080p/mp4/file.mp4

At CLD Legal, we assist companies and multinational groups in the legal and tax analysis of their corporate structures. - info@cldlegal.com