Panama Tax and Regulatory Updates: August–September 2026

Raúl González Casatti

13 October, 2026
Articles, Newspaper tax

This edition brings together tax and regulatory developments affecting businesses, financial institutions, property developers, and international groups with Panamanian entities.

Our five featured updates cover aviation customs exemptions, new home transfer tax relief, mortgage subsidy payments, economic substance regulations, and accounting records compliance. We also review additional DGI measures and two decisions on taxpayer safeguards during audits.

Five Featured Updates at a Glance

Development	Main business relevance
Panama–Saudi Arabia Air Services Agreement	Customs treatment of specified airline equipment and supplies
New home transfer tax exemption	Tax assessment before a qualifying first sale
Mortgage interest subsidy payments	Recovery planning for mortgage lenders
Economic substance regulations	Preparation for fiscal periods beginning in 2027
DGI Law 52 non-compliance list	Review of accounting compliance and corporate status

1. Panama–Saudi Arabia Air Services Agreement: Customs Exemptions

Law 548 of September 9, 2026

Panama approved the Air Services Agreement signed with Saudi Arabia in Paris on June 16, 2025.

Article 6 provides customs and tax exemptions for specified aircraft, equipment, spare parts, fuel, lubricants, and onboard supplies associated with designated airlines, subject to the agreement’s conditions. Article 5 addresses airport charges separately.

Business action: Airlines and suppliers should review the recipient airline, intended use of the goods, and supporting documents before including anticipated customs relief in quotations or operating budgets.

Read the full analysis of the Panama–Saudi Arabia agreement and customs exemptions.

Related service: International Tax Advisory.

Official source: Law 548 of 2026.

2. New Residential Property: Transfer Tax Relief on the First Sale

Law 546 of August 31, 2026

Law 546 amends the Real Estate Transfer Tax rules, known as ITBI, for qualifying first sales of new residential properties.

The benefit exempts the first B/.120,000 of the taxable base. Preferential rates apply to the excess for taxable bases above that threshold and up to B/.200,000. Higher amounts retain the initial exemption, with general rules applying to the excess.

Eligibility also depends on the applicable occupancy permit deadline and deed requirements.

Business action: Developers and transaction advisers should verify eligibility, the taxable base, and the closing timeline before calculating the tax.

Read the full analysis of Panama’s new home transfer tax exemption.

Related services: Domestic Tax Advisory · Real Estate Legal Services.

Official source: Law 546 of 2026.

3. Mortgage Interest Subsidies: Three Settlement Methods for Lenders

Executive Decree 36 of September 17, 2026

The decree regulates Law 468 of 2025, as amended by Law 481 of 2025, and replaces the previous implementing regulations.

Recognized subsidies may be satisfied through tax credits, bank transfers, or public debt securities, subject to the applicable conditions. Bank transfers and securities are not automatic entitlements, and receiving securities does not guarantee immediate conversion into cash.

Business action: Mortgage lenders should reconcile subsidy claims, distinguish pending amounts from recognized amounts, and assess the tax and liquidity implications of the expected settlement method.

Read the full analysis of mortgage interest subsidy payments in Panama.

Related services: Tax Management and Compliance · Banking and Finance.

Official source: Executive Decree 36 of 2026.

4. Economic Substance: Implementing Regulations for Law 526

Executive Decree 32 of September 2, 2026

The regulations develop the economic substance requirements for specified foreign-source passive income earned by entities within scope.

They address human resources, premises, strategic decision-making, operating expenses, outsourcing, reporting, and simplified treatment for qualifying holding entities. They apply to fiscal periods beginning on or after January 1, 2027.

Business action: International groups should assess each Panamanian entity, identify the applicable requirements, and prepare supporting documentation before the relevant fiscal period begins.

Read our full analysis of Executive Decree 32 and Panama’s economic substance requirements.

Related service: International Tax Advisory.

Official source: Executive Decree 32 of 2026.

5. DGI Publishes a Law 52 Non-Compliance List

Resolution 201-5965 of July 30, 2026 | Published August 12, 2026

The resolution publishes a list of legal entities identified as non-compliant with Law 52 accounting information obligations and orders the Public Registry to record the suspension of their corporate rights.

The resolution also addresses reactivation through correction of the cause and payment of the applicable fine.

Business action: Owners and resident agents should confirm any matching entry, review the underlying file, and verify current registry status. Accounting information compliance and annual franchise tax payments should be reviewed separately.

Read the full analysis of the DGI Law 52 list and corporate status checks.

Related services: Tax Management and Compliance · Accounting Services.

Official source: Resolution 201-5965 of 2026 and its annex.

Additional DGI Updates

CRS Participating Jurisdictions

Resolution 201-5324 of July 15, 2026

Adopts the list of participating jurisdictions for Common Reporting Standard information exchange.

Review point: Reporting financial institutions should check the adopted list when assessing their obligations.

Official source: Resolution 201-5324.

CRS Reporting When No Accounts Are Reportable

Resolution 201-5325 of July 15, 2026

Regulates the declaration required from reporting Panamanian financial institutions when no reportable accounts are identified for the relevant calendar year.

Review point: Finding no reportable accounts should not be treated as eliminating the declaration requirement.

Official source: Resolution 201-5325.

Reporting Undocumented Accounts

Resolution 201-5326 of July 15, 2026

Establishes procedures for identifying, managing, and reporting undocumented accounts under the applicable information exchange framework.

Review point: Financial institutions should review due diligence records, account classification, and supporting evidence.

Official source: Resolution 201-5326.

Related advisory: International Tax and Reporting Services.

Authentication of Documents Before the DGI

Resolution 201-5151 of July 13, 2026

Amends the delegation of authority to specified officials for authenticating documents.

Official source: Resolution 201-5151.

Tax Treaty Negotiation Team

Resolution 201-4841 of July 6, 2026

Establishes and appoints the DGI team responsible for negotiating international tax treaties or agreements.

Official source: Resolution 201-4841.

Selected Tax Tribunal Decisions: Safeguards During DGI Audits

Audit Periods Must Be Properly Communicated

TAT-RF-034 of August 21, 2026 | Case 003-2026

The Administrative Tax Tribunal partially annulled a business operating notice tax assessment for 2010 and 2011 because those periods had not been included in the audit scope communicated for that tax. The assessment for the notified periods remained in place.

The Tribunal also distinguished the suspensive effect of administrative appeals from suspension of the tax limitation period.

Practical takeaway: Compare the taxes and periods in an assessment with the audit notice, and evaluate limitation periods separately.

Read the full decision.

Effective Notice and an Opportunity to Respond

TAT-NUL-019 of July 3, 2026 | Case 042-2025

The Tribunal emphasized effective notification of the audit and a meaningful opportunity for the taxpayer to explain, provide evidence, and challenge findings before an assessment is issued.

In the case reviewed, failures affecting those safeguards led to absolute nullity of the challenged administrative acts.

Practical takeaway: Retain notification records and evidence of opportunities provided to respond during the audit.

Read the full decision.

Related services: Tax Audit Advisory · Administrative Law.

Do These Developments Affect Your Business?

LAC Tax can help assess the implications for your operations, review supporting documents, and coordinate the relevant tax and legal work.

Request a consultation · Contact us via WhatsApp · Email our tax specialist.

Raúl González Casatti
Email: rgonzalez@lacgrp.com
Telephone: +507 6798-9529

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This newsletter provides general information and does not replace review of the official legal texts or advice tailored to a specific situation. Official sources linked above are in Spanish.