An additional tax assessment (liquidación adicional) from Panama’s Directorate General of Revenue (DGI) establishes a difference between the tax reported and what the authority considers legally due. Taxpayers can challenge this decision through administrative remedies—starting with a reconsideration appeal before the DGI (typically within 15 business days of notification) or an appeal before the Tax Administrative Tribunal (TAT)—and subsequently through judicial proceedings before the Third Chamber of the Supreme Court of Justice.
An additional tax assessment from Panama’s Directorate General of Revenue (DGI) means the authority has determined that a taxpayer owes more tax than originally reported or paid. It does not mean the taxpayer has no further opportunity to challenge that determination.
The immediate priority is to establish the notification date and protect the deadline for challenging the assessment. The next step is to examine each adjustment, its supporting evidence and the procedure followed by the DGI.
Depending on the applicable rules, the dispute may proceed through reconsideration before the DGI, an appeal to the Tax Administrative Tribunal (TAT) and, after administrative remedies have been exhausted, judicial proceedings before the Third Chamber of Panama’s Supreme Court of Justice.
What Is an Additional Tax Assessment?
An additional assessment—known in Panama as a liquidación adicional—determines a difference between the tax reported or paid and the amount the DGI considers legally due.
Typical disputes concern:
- Income the authority considers unreported.
- Expenses or costs rejected as deductions.
- The application of an exemption or tax incentive.
- The tax classification of a transaction.
- The taxable base or rate used in the calculation.
An additional assessment is different from a penalty. The assessment determines a tax difference, while a penalty addresses a specific infringement. Interest and surcharges may also apply, depending on the circumstances.
For guidance on the earlier stages of an investigation, see our practical guide to responding to a tax audit in Panama.
What Should You Do After Receiving a DGI Assessment?
1. Confirm the Notification Date and Applicable Deadline
Keep the complete resolution and evidence of how and when it was notified. These records are essential to calculating the deadline.
The DGI’s published procedural requirements identify a 15-business-day period for submitting a substantiated reconsideration appeal, counted from the day following notification. The governing procedure and calculation must be checked for the particular case.
Do not postpone legal review until every supporting record has been collected. Evidence preparation and deadline protection should proceed together.
2. Separate the Adjustments and Amounts Claimed
Review the assessment item by item. Distinguish additional tax from interest, surcharges and penalties, and identify the reason given for each adjustment.
| Review area | Key question |
|---|---|
| Tax and period | Which tax and fiscal year are being assessed? |
| Additional income | What transaction and evidence support the adjustment? |
| Rejected deductions | Which requirement does the DGI consider unmet? |
| Taxable base and rate | How was the additional tax calculated? |
| Interest, surcharges and penalties | What legal basis and calculation support each amount? |
| Reasons for the decision | Does the resolution explain the facts, evidence and applicable law? |
| Audit procedure | Were the relevant procedural steps and opportunities to respond respected? |
3. Build an Evidence File for Each Disputed Item
Collect the relevant returns, accounting records, invoices, contracts, payment evidence and correspondence with the DGI.
Preserve audit records, information requests, responses and notification documents as well. These help reconstruct the process that led to the assessment.
Each document should be linked to the adjustment it addresses. A coordinated legal and accounting review helps explain why the evidence supports the taxpayer’s position. Our LAC TAX team assists with this analysis.
Was There an Opportunity to Respond Before the Final Assessment?
A proposed adjustment, referred to as a propuesta de regularización, is different from a final additional assessment.
In cases governed by Article 208 of Panama’s Tax Procedure Code, this stage communicates proposed adjustments and provides 10 business days to agree fully or partially, or present arguments in response.
The TAT has examined failures to issue audit closure records and proposed adjustments in assessment disputes. One example is Resolution TAT-NUL-050 of November 21, 2025.
The proposed adjustment is not challenged through the same remedies as the final assessment. Its practical importance lies in the opportunity to address findings before a final determination is issued.
What Are the Options for Challenging the Assessment?
Reconsideration Before the DGI
A reconsideration appeal asks the authority to review its determination, including the adjustments and evidence supporting the amount claimed.
The submission should identify the contested findings, explain the requested outcome and provide legal arguments supported by evidence.
Our guide to reconsideration appeals before Panama’s DGI explains this remedy in greater detail.
Appeal to the Tax Administrative Tribunal
An adverse reconsideration decision may be challenged before the TAT, subject to the applicable filing requirements and deadlines.
Counsel should also assess whether the governing procedure permits a direct appeal without first seeking reconsideration. This choice requires examination of the resolution and the rules applicable to the case.
The appeal may address both the substantive adjustments and relevant procedural objections.
Judicial Proceedings Before the Supreme Court
After administrative remedies have been exhausted, a taxpayer may be able to bring a full-jurisdiction administrative claim before the Third Chamber of Panama’s Supreme Court of Justice.
This judicial stage has its own admissibility requirements, deadlines and rules concerning the decision being challenged and the relief requested. It should be assessed separately from the administrative appeal.
What Grounds Can Support a Tax Assessment Challenge?
The strongest arguments depend on the particular adjustments and the evidence available.
Potential grounds include:
- Factual errors: income attributed incorrectly or conclusions based on incomplete information.
- Evidence assessment: relevant records overlooked or evaluated incorrectly.
- Legal interpretation: disputed treatment of deductions, rates, exemptions or incentives.
- Calculation errors: mistakes in the taxable base or amounts claimed.
- Procedural defects: omissions affecting the applicable procedural safeguards or right of defence.
Both the tax calculation and the audit procedure matter. A disagreement over the amount and an objection to the legality of the process require distinct analysis.
Our strategic tax advisory for businesses supports the assessment of these issues and their implications for the company.
Mistakes That Can Weaken Your Defence
Common mistakes include:
- Missing the filing deadline.
- Expressing disagreement without addressing the DGI’s reasoning.
- Providing records without explaining their relevance.
- Confusing a proposed adjustment with a final assessment.
- Assuming that filing an appeal automatically suspends collection.
- Overlooking the deadline for the next administrative or judicial stage.
Maintaining complete records through tax management and compliance services can support the preparation of a documented response.
Frequently Asked Questions About Panama Tax Assessment Appeals
Does an Additional Assessment Mean I Committed Tax Evasion?
Not necessarily. An assessment may arise from differences over legal interpretation, deductions, records or calculations. Tax evasion requires a separate analysis.
Can I Challenge Only Part of the Assessment?
A challenge may focus on specific adjustments. Counsel should determine the scope of the appeal and how any uncontested amounts should be treated.
What Should I Give My Lawyer First?
Provide the complete resolution and notification evidence. These establish the decision being challenged and the information needed to calculate the deadline.
Are Invoices Enough to Defend a Deduction?
The evidence must address the reason for rejection. Invoices may need to be supported by contracts, payment records and an explanation of the transaction.
Can I Dispute Expenses Rejected by the DGI?
Yes, where there are legal grounds and supporting records. The analysis depends on the expense and the authority’s stated reasons for rejecting it.
What Happens if Reconsideration Is Unsuccessful?
An appeal to the TAT should be assessed promptly, with particular attention to the filing deadline and requirements.
Must I Always Request Reconsideration Before Appealing?
The availability of a direct appeal depends on the governing procedure. It should be verified before choosing the route.
Does a Procedural Error Automatically Invalidate the Assessment?
No. The omitted step, applicable rule and effect on the proceedings or right of defence must be examined.
Can I Take the Dispute to Court After the TAT?
After administrative remedies have been exhausted, proceedings before the Supreme Court’s Third Chamber may be available, subject to judicial requirements and deadlines.
Legal Representation in Panama Tax Assessment Disputes
At LAC Legal, together with LAC TAX, we review DGI adjustments, examine audit files and develop the administrative or judicial defence appropriate to each case.
Received an additional tax assessment in Panama? Contact our team to review the resolution, confirm the deadline and assess your options.