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ARTICLE · 22 SEPTEMBER 2026

Economic Substance In Panama: Requirements And 2027 Deadline

A holding company incorporated in Panama that never had an office or employees, and that only receives dividends from a subsidiary in another country, is exactly one of the types of structures targeted by Law 526, which amends the Central American country’s Fiscal Code. That model, used for years in hundreds of wealth and corporate structures registered in Panama, will no longer be sufficient on its own starting in fiscal year 2027, when the new economic substance regime takes effect.

PanamaStrategy

By: Gunther Felix – Collaboration with Mariano J. Oteiza D. for Lex Latin

A holding company incorporated in Panama that never had an office or employees, and that only receives dividends from a subsidiary in another country, is exactly one of the types of structures targeted by Law 526, which amends the Central American country’s Fiscal Code. That model, used for years in hundreds of wealth and corporate structures registered in Panama, will no longer be sufficient on its own starting in fiscal year 2027, when the new economic substance regime takes effect.

The law, enacted on May 28, 2026 in Official Digital Gazette No. 30534-B, requires Panamanian entities that are part of a multinational group to demonstrate that decisions on that passive income are made in Panama, backed by staff, offices, and operating expenses that support that activity. Those who fail to do so will pay a 15% tax on net foreign-source income.

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