{"id":3207,"date":"2026-06-21T23:41:17","date_gmt":"2026-06-21T23:41:17","guid":{"rendered":"https:\/\/limayasociados.com\/?p=3207"},"modified":"2026-06-22T02:04:38","modified_gmt":"2026-06-22T02:04:38","slug":"ley-526-panama-ingreso-exterior-territorialidad","status":"publish","type":"post","link":"https:\/\/limayasociados.com\/en\/ley-526-panama-ingreso-exterior-territorialidad\/","title":{"rendered":"\u00bfSigue tu ingreso del exterior sin pagar impuestos en Panam\u00e1? Lo que la Ley 526 cambi\u00f3 (y lo que no)"},"content":{"rendered":"

Panama's Law 526<\/strong>, signed on May 28, 2026, modified the treatment of certain passive income of foreign source within the Fiscal Code. The press called it \"territoriality 2.0,\" and it raised questions among foreign residents, digital nomads and investors about whether Panama still leaves foreign income untaxed.<\/p>\n\n\n\n

This article summarizes what Law 526 introduces, which aspects of the territorial system it does not modify, and a point that often stays out of the conversation: its implementing regulation has not yet been published, which leaves several practical elements undefined.<\/p>\n\n\n\n

What the law introduces: economic substance requirements<\/h2>\n\n\n\n

Law 526 added a new chapter to the Fiscal Code with economic substance requirements<\/strong> for certain passive income of foreign source. The regime is set to apply from tax period 2027<\/strong>.<\/p>\n\n\n\n

Its logic aligns with international standards against base erosion: certain entities that receive passive income from abroad must show real substance in Panama \u2014presence, staff, expenses, effective management\u2014 and not operate as mere conduit structures. According to the text of the law, an entity covered by the regime that does not show such substance over the income concerned could be subject to a 15% tax on net taxable income<\/strong>, starting in fiscal year 2027.<\/p>\n\n\n\n

The implementing regulation has not yet been published<\/h2>\n\n\n\n

A law of this nature is applied through an implementing regulation<\/strong> \u2014the executive decree that develops it\u2014 which is what sets out what matters in practice: the exact scope of the regime, which entities are covered and which are excluded, how substance is demonstrated, what documentation is required, the procedures and deadlines, and the criteria by which the General Directorate of Revenue will interpret and enforce it.<\/p>\n\n\n\n

As of the publication date of this article, that regulation has not been issued. Until it is, several aspects of the regime remain undefined, and conclusions about how it will affect a specific structure are necessarily preliminary. This is a relevant fact when assessing any decision: it is worth distinguishing between what the law already establishes and what will still depend on its regulation.<\/p>\n\n\n\n

What Law 526 does not change<\/h2>\n\n\n\n

Beyond the pending regulation, the text of the law makes its limits clear. Law 526 does not alter the following:<\/p>\n\n\n\n