Countries › Panama › Guide › 3. Investing › Choosing an investment regime in Panama: general regime, ten year stability, SEM, EMMA, Panama Pacífico or a free zone
Choosing an investment regime in Panama: general regime, ten year stability, SEM, EMMA, Panama Pacífico or a free zone
Last verified: 2026-10-29 · Status: Stable
Most foreign investors in Panama operate under the general regime: a territorial 25 percent income tax and 10 percent dividend tax on Panamanian source profits, with free repatriation. Group service hubs look at the SEM licence, group manufacturing and repair operations at EMMA or a free zone, and aviation, logistics, data and shared service operations at Panama Pacífico, while large projects in listed sectors can freeze their tax regime for ten years. This page compares them from the laws and points to the detailed pages.
Panama's currency, the balboa (B/.), is at par with the US dollar, which circulates as legal tender (Ley 84 de 1904; see fx/dollarization-and-the-balboa). USD figures therefore equal the balboa figures.
Key facts
| Corporate income tax general rate | 25 %Código Fiscal art. 699, as of 2026-10-29 · in force |
|---|---|
| Dividend tax on Panamanian source profits | 10 %Código Fiscal art. 733 literal a, as of 2026-10-29 · in force |
| Dividend tax for free zone companies (any source) | 5 %Ley 32 de 2011 art. 32 numeral 2, as of 2026-10-29 · in force |
The rule
| Regime | Fits | Income tax | Dividend tax | Entry test | Substance test |
|---|---|---|---|---|---|
| General regime | Any business selling in Panama | 25 percent on Panamanian source income | 10 percent (5 percent on foreign source or export profits) | None | No |
| Ley 54 stability | Projects in listed sectors | Rate in force at registration, frozen 10 years | As frozen | Plan of at least B/.2,000,000 | Execution of the plan |
| SEM | Group headquarters and shared services | 5 percent (2 percent floor with credits) | Exempt | US$200 million group assets or more than 40 countries | Yes, yearly |
| EMMA | Group manufacturing, assembly, repair, testing, logistics | 5 percent (2 percent floor with credits) | Exempt | Set by the licensing Commission | Yes, yearly |
| Panama Pacífico | Aviation, high technology, data, logistics, shared services | Exempt for listed activities; 5 percent for office services; else general | General rules, with special rules for trade and logistics | Registration with the Agency | Yes for data, logistics and office services |
| Free zone (Ley 32 de 2011) | Export manufacturing and services | Exempt on exterior operations for listed company types | 5 percent | Licence in a licensed free zone | Not in Ley 32 |
Main regimes compared, from the laws cited on this page and the linked pages.
Worked example
- A Chilean group plans three things in Panama: a regional finance and HR hub, a spare parts repair workshop for its subsidiaries and a sales office for Panamanian customers.
- The hub fits an SEM licence (5 percent on its cost based income, no dividend tax), if the group meets the asset or country test.
- The workshop fits EMMA (5 percent, duty free equipment) or a free zone; at B/.500,000 (US$500,000) of net income, 5 percent means B/.25,000 of tax against B/.125,000 at 25 percent.
- The sales office stays in the general regime: 25 percent on its profits and 10 percent dividend tax on distributions, with free repatriation.
Step by step
- List each activity and who the customers are: group companies, foreign clients or Panamanian buyers.
- Match group only services to SEM or EMMA, export operations to a free zone or Panama Pacífico, and domestic sales to the general regime.
- Check entry tests (group size, investment amount, registration) and the yearly substance rules.
- Check the constitutional limits, especially the retail trade reservation, before setting up a domestic sales channel.
- Model the tax: income tax, dividend tax, withholding on payments abroad and any capital tax.
- Use separate companies where activities fall under different regimes; SEM and EMMA require it for activities outside the licence.
Common traps
- Incentive regimes cover exports and group services; sales into Panama are taxed under general rules almost everywhere.
- SEM, EMMA and Panama Pacífico benefits are lost year by year if staff and spending in Panama are not adequate.
- An EMMA located in a free zone or Panama Pacífico gets only the EMMA tax regime.
- Panama has no tax treaty with Argentina, so Argentine owners face domestic withholding rates on payments from any of these regimes.
Sources
- Ley 8 de 15 de marzo de 2010 (Código Fiscal art. 699)
- Ley 8 de 4 de abril de 2016 (Código Fiscal art. 733)
- Ley 32 de 5 de abril de 2011, free zones
- Ley 57 de 24 de octubre de 2018 (SEM)
- Ley 159 de 31 de agosto de 2020 (EMMA)
- Ley 66 de 13 de diciembre de 2018 (Panama Pacífico)
- Ley 54 de 22 de julio de 1998 (stability)
- Resolución 20-17 de 2017 (SEM requirements)
Related pages
- investing/multinational-headquarters-sem
- investing/emma-manufacturing-services
- investing/panama-pacifico-special-economic-area
- investing/legal-stability-regime
- trade/free-zones
- trade/colon-free-zone
- taxes/tax-incentives
- entities/choosing-an-entity
- https://theargentinethread.com/guide/
- /country/panama/
- /calendar/
- Live dashboard
Related: Panama country profile · live dashboard · central bank and release calendar · our posts on X
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