The Ministry of Economy and Finance (MEF) has approved and published the regulations implementing Law 526 of May 28, 2026, which establishes economic substance requirements applicable to entities incorporated or domiciled in Panama that are part of a multinational group and receive certain categories of passive foreign-source income.
What does this mean?
The regulations establish the parameters and criteria that entities subject to the rules must meet to demonstrate that they maintain the required economic substance in Panama, in line with the new obligations introduced by Law 526.
Who is affected?
Primarily, Panamanian entities belonging to multinational groups that derive certain categories of passive income from foreign sources. These entities will be subject to specific requirements regarding activities, presence, and compliance.
Importance for Multinational Groups
The new regulations represent a significant step in the implementation of Panama’s economic substance regime and make it necessary to review the corporate structures, operations, functions, and documentation of entities that may fall within its scope.
Molina & Co. will continue monitoring the implementation of this legislation and its implications for multinational groups with a presence in Panama.
For advice regarding the scope of Law 526 and its implementing regulations,
please contact us.