For mortgage lenders participating in Panama’s preferential interest regime, recovering the government subsidy requires coordination between loan administration, tax reporting, and treasury management.
Executive Decree 36 of September 17, 2026, regulates Law 468 of 2025, as amended by Law 481 of 2025, and replaces the regulations established by Executive Decree 23 of June 2026.
The recognized subsidy may be satisfied through tax credits, bank transfers, or public debt securities, subject to the applicable conditions. Lenders should assess both the status of the subsidy claim and the settlement method before incorporating expected recovery into their financial projections.
How Do the Three Payment Methods Differ?
Each method calls for a different operational review:
| Payment method | Main review area for the lender |
| Tax credit | Recognition, posting, and movements in the lender’s tax account |
| Bank transfer | Eligibility, request status, budgetary conditions, and payment tracking |
| Public debt securities | Authorization, instrument terms, and liquidity requirements |
We recommend involving the tax, finance, and treasury teams in this assessment. The settlement method can affect when and how a recognized amount becomes available for the lender’s intended use.
LAC Tax’s domestic tax advisory services can support the review of the relevant tax treatment.
How Is the Mortgage Subsidy Tax Credit Applied?
Panama’s Directorate General of Revenue, or DGI, credits, offsets, and records the recognized tax credit in the lender’s tax account. The recognition decision is communicated through Panamá Conecta.
As an internal control measure, we recommend reconciling recognized amounts against the lender’s tax and accounting records.
The supporting file should make it possible to identify the relevant period, the underlying loans, and subsequent movements affecting the credit.
What to Review Before Using or Transferring a Tax Credit
Before taking action, lenders should consider checking:
- The administrative decision supporting recognition.
- The recorded amount and its availability.
- Previous applications or transfers.
- The applicable tax procedure.
- The documents retained by each responsible team.
This work can form part of a broader tax management and compliance review.
Conditions for Bank Transfers and Public Debt Securities
Recognized subsidies of up to B/.2 million may be paid by bank transfer at the lender’s request, subject to budgetary and financial rules.
For higher amounts, the decree permits public debt securities with prior Cabinet Council authorization. Their delivery does not guarantee immediate conversion into cash.
These methods are not automatic entitlements. Replacing a recognized tax credit requires the lender’s express consent, preservation of the recognized subsidy amount, and cancellation of the credit before implementing the replacement method.
Assess the Effect on Liquidity
We recommend preparing scenarios that distinguish the recognized amount, the expected settlement method, and the estimated timing of availability.
For securities, the financial assessment should consider the instrument’s terms and whether the lender expects to hold it or seek liquidity through a transaction.
For bank transfers, the responsible team should track the request and its processing status.
These are financial management recommendations. The specific accounting treatment should be assessed against the institution’s circumstances and applicable standards.
Keep Subsidy Claims and Settlement Records Reconciled
A consistent tracking process helps the lender’s teams work from the same information.
We recommend maintaining the following controls:
| Tracking item | Purpose |
| Claim period and related loan portfolio | Connect the amount to its underlying transactions |
| Submitted documentation | Identify the available supporting evidence |
| Administrative status | Distinguish pending claims from recognized amounts |
| Expected settlement method | Coordinate tax or treasury follow-up |
| Subsequent movements | Detect differences between records |
| Internal owner | Assign responsibility for questions and pending actions |
This structure can help identify incomplete files and support responses to questions from authorities, auditors, or internal reviewers.
A tax audit review may also help assess the consistency of supporting accounting records.
Practical Recommendations for Banks and Mortgage Lenders
Before incorporating subsidy recovery into financial projections, we recommend:
- Reconcile the amounts. Compare loan portfolio information, supporting documents, and available records.
- Confirm the claim’s status. Separate submitted claims from recognized amounts.
- Assess the settlement method. Review its conditions before estimating availability.
- Document decisions. Retain relevant requests, administrative decisions, and consents.
- Coordinate internal records. Keep tax, accounting, and treasury information consistent.
Where the assessment also involves financing contracts or banking matters, it can be complemented by banking and finance legal advice.
Frequently Asked Questions
1. Which regulation should lenders consult?
Executive Decree 36 of September 17, 2026, together with the legislation it regulates. The official text is in Spanish.
2. Who is this guidance intended for?
Banks and other mortgage lenders managing recognized subsidies under Panama’s preferential mortgage interest regime.
3. What should a lender review first?
We recommend identifying the amount claimed, its supporting evidence, and the administrative status of the file.
4. How should a lender prepare for a tax credit review?
Bring together the recognition decision, tax account records, and details of subsequent credit movements.
5. What should the treasury team assess?
The expected settlement method, its conditions, and the institution’s liquidity needs.
Review Your Mortgage Subsidy Recovery Process
LAC Tax can assist your institution with supporting documentation, tax credit reconciliation, and assessment of the available subsidy settlement methods.
Our tax advisory team in Panama can coordinate the review with the institution’s legal, finance, and accounting teams.
Contact LAC Tax to discuss your mortgage subsidy arrangements.
Specialist contact: Raúl González Casatti.
Email: rgonzalez@lacgrp.com
Legal source: Executive Decree 36 of September 17, 2026, published in Official Gazette 30614-C.