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Reform tracker: what changed in Panamanian business law in 2025 and 2026 and what starts in 2027

Argentina. For full detail on Argentina, go to The Argentine Thread.

Last verified: 2026-10-29 · Status: Changing

Already in force: the Caja de Seguro Social reform of March 2025, the oral Código Procesal Civil from 11 October 2025, the dissolution of suspended companies that began on 27 February 2026 and the August 2026 transfer tax exemption for new homes. Coming in 2027: economic substance rules for foreign passive income from fiscal year 2027 and the employer social security step to 14.25 percent on 1 March 2027. Pending: a bill to apply the 7 percent ITBMS to digital services supplied from abroad, and an announced amendment of Ley 32 de 1927 to expressly prohibit bearer shares.

Panama's currency, the balboa (B/.), is at par with the US dollar, which circulates as legal tender; the Superintendencia de Bancos states that the official currency is the balboa, whose value is on a par with the United States dollar (checked 29 October 2026). USD figures therefore equal the balboa figures.

Key facts

Rate on foreign passive income of non qualifying group entities15 %Ley 526 de 2026, as of 2026-10-29 · pending
Employer social security rate from 1 March 202714.25 %Ley 462 de 2025, as of 2026-10-29 · pending
Employer social security rate from 1 March 202915.25 %Ley 462 de 2025, as of 2026-10-29 · pending
Entities in the first dissolution stage290534 entitiesDGI 2016 resolutions; Código Fiscal art. 318-A, as of 2026-10-29 · in force
Transfer tax exempt base on first sale of a new home120000 PABLey 546 de 2026, as of 2026-10-29 · in force

The rule

1. Ley 526 de 2026 adds an economic substance chapter to the Código Fiscal: foreign source passive income of non qualifying entities of multinational groups is taxed at a single and final 15 percent on net taxable income. The law applies from fiscal year 2027.Ley 526 de 28 de mayo de 2026, art. 1 (Código Fiscal art. 707-D) and art. 6, 2026-05-28 official text · verified 2026-10-29 · changed: Enacted 28 May 2026 (Gaceta Oficial 30534-B); effective from fiscal year 2027. Status: in force, applying from 2027.
2. The Caja de Seguro Social reform sets the employer contribution at 13.25 percent from its entry into force until 28 February 2027, 14.25 percent from 1 March 2027 to 28 February 2029 and 15.25 percent from 1 March 2029; the employee rate stays at 9.75 percent.
Example: Employer cost on a B/.1,500 salary: B/.198.75 now, B/.213.75 from March 2027, B/.228.75 from March 2029. / US$198.75, US$213.75 and US$228.75 a month.Ley 462 de 18 de marzo de 2025, amending Ley 51 de 2005 art. 101, art. 84, 2025-03-18 official text · verified 2026-10-29 · changed: Enacted 18 March 2025; next employer step 1 March 2027, final step 1 March 2029.
3. The new Código Procesal Civil enters into force throughout the country two years after its promulgation; it was published in Gaceta Oficial 29887-A on 11 October 2023, so it governs new civil and commercial cases from 11 October 2025.Ley 402 de 2023, Código Procesal Civil, art. 809, 2023-10-11 official text · verified 2026-10-29 · changed: Oral civil procedure in force from 11 October 2025.
4. By Resolución 201-0977 of 29 January 2026 the DGI published the list of legal entities three consecutive years delinquent on the tasa única and ordered their suspension to be noted. The MEF announced that dissolution of suspended entities would start on 27 February 2026, beginning with 290,534 entities that received dissolution annotations under 2016 DGI resolutions, in a first block of 180,883 companies.DGI Resolución 201-0977 de 29 de enero de 2026; Código Fiscal art. 318-A, Resolución 201-0977, 2026-01-29 official text · verified 2026-10-29 · changed: Suspension list published 4 February 2026; dissolutions under way since 27 February 2026.
5. Ley 546 de 2026 rewrites article 4 of Ley 106 de 1974: the first sale of a new home formalized within two years of the occupancy permit is exempt from real estate transfer tax on the first B/.120,000 of the taxable base, with a preferential scale of 0.50 to 1.80 percent on the excess for bases up to B/.200,000. The law took effect the day after promulgation.
Example: A new home sold for a taxable base of B/.125,000 pays 0.50 percent on B/.5,000, that is B/.25. / US$25.Ley 546 de 31 de agosto de 2026, amending Ley 106 de 1974 art. 4, arts. 1 and 4, 2026-08-31 official text · verified 2026-10-29 · changed: In force from the day after promulgation on 31 August 2026.
6. Ley 489 de 2025 approved Economic Complementation Agreement 76 between the Mercosur States Parties signatory to the Treaty of Asunción (Argentina, Brazil, Paraguay and Uruguay) and Panama, signed in Montevideo on 6 December 2024.Ley 489 de 13 de octubre de 2025, art. 1, 2025-10-13 official text · verified 2026-10-29 · changed: Approved by Panama on 13 October 2025; the Argentine side of trade with Panama is covered in The Argentine Thread guide.
7. On 21 August 2026 the MEF explained a measure under which foreign platforms supplying digital services in Panama would register with the DGI and apply and remit the existing 7 percent ITBMS; the MEF stated it is not a new tax and the rate does not change.MEF explanatory note on the ITBMS bill for digital services, Bill (not enacted as of 29 October 2026 on the information verified), 2026-08-21 official text · verified 2026-10-29 · changed: Status: pending bill announced August 2026.
8. In announcing the 2026 dissolutions, the MEF said the Government is preparing a targeted amendment of Ley 32 de 1927 limited to an express prohibition on issuing bearer shares, in response to updates to FATF Recommendation 24.MEF announcement of 4 February 2026, Announcement, 2026-02-04 official text · verified 2026-10-29 · changed: Status: announced reform, no enacted law verified as of 29 October 2026.
ReformNormEffectiveStatus
Economic substance for foreign passive income, 15 percentLey 526 de 2026Fiscal year 2027Enacted, applies from 2027
Employer social security 14.25 percent, then 15.25 percentLey 462 de 20251 March 2027; 1 March 2029Enacted, scheduled
Oral Código Procesal CivilLey 402 de 202311 October 2025In force
Dissolution of suspended legal entitiesDGI Res. 201-0977; Código Fiscal art. 318-AFrom 27 February 2026Under way
Transfer tax exemption for first sale of new homesLey 546 de 2026From 1 September 2026In force
Mercosur ACE 76Ley 489 de 2025Approved 13 October 2025Approved by Panama
ITBMS on digital services from abroadMEF billNot setPending
Express ban on bearer sharesAnnounced amendment of Ley 32 de 1927Not setAnnounced

Panama reform tracker (status at 29 October 2026)

Worked example

  • A regional holding company in Panama that receives B/.2,000,000 of foreign dividends each year has until the end of 2026 to prepare its substance file; if it is a non qualifying entity in 2027 it would owe B/.300,000 (US$300,000) at 15 percent on that income.

Step by step

  1. Review group structures against the substance tests before 1 January 2027.
  2. Update 2027 payroll budgets for the 1 March 2027 social security step.
  3. Check the Registro Público status of every Panamanian entity in the group, given the dissolutions under way.
  4. Follow the digital services ITBMS bill if you sell online services into Panama from abroad.

Common traps

  • An entity dissolved for unpaid tasa única loses its capacity; check status before signing contracts with Panamanian counterparties.
  • Ley 526 applies by fiscal year, so 2027 income is affected even though the law dates from May 2026.
  • Announced reforms and bills are not law; plan for them but do not treat them as in force.

Sources

Related pages

Related: Panama country profile · live dashboard · central bank and release calendar · our posts on X

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