Panama: individual tax scope
Individual income tax focuses on income legally sourced in Panama, not on a passport or where payment arrives. Fiscal residence has alternative presence and permanent-home criteria, and foreign-source classification and treaty relief require separate checks.
Fiscal-residence day test
An individual is fiscally resident after more than 183 days, consecutive or intermittent, in Panama in a fiscal year or the immediately preceding year. This tax test is distinct from nationality and immigration documentation.
Alternative permanent-home route
A permanent home can establish fiscal residence without satisfying the day test. The tax tribunal explains that the home, economic interests and family interests require substantive assessment: merely owning or renting an available property does not establish residence automatically.
Domestic-source income
Article 694 taxes income produced within Panama irrespective of where it is received and covers national and foreign individuals. Nonresidence is not a blanket exemption: specified services benefiting a Panamanian recipient can be domestic source where they support Panamanian-source income and are deducted by the recipient.
Foreign-source reporting is separate
DGI's individual-return instructions require entering domestic, foreign and exempt income, then separately remove qualifying foreign-source income when calculating taxable receipts. Foreign payment or a foreign client alone does not determine source; Article 694 and special rules govern the classification.
Residence evidence and treaties
A residence-certificate request identifies the treaty or general use and the year concerned. DGI asks individuals for migration movements, identity, housing and other Panama-link evidence. A certificate application is not automatic treaty relief; the applicable convention and facts must be checked.
Scope and limitations
- General information, not a personalised tax calculation. Income classification, withholding, filing and treaty conditions require individual assessment.
- Article 694's official restoration and the 2015 amendment to paragraph 1(e) are read alongside the currently posted DGI individual-return instructions; this is not represented as a full 2026 consolidated Fiscal Code. The services example is not exhaustive: paragraph 1(e) also has rules for public bodies, non-taxpayers and taxpayers in loss.
- The tribunal decision supports residence criteria and evidentiary limits, not a guarantee that another applicant will obtain a certificate.
Next review due . An official update can change these requirements sooner.
Official sources
- Law 1 of 2014 restoring Fiscal Code Article 694Gaceta Oficial de Panamá · Retrieved 2026-09-22 · ES
- Law 27/2015 — Article 694(1)(e) amendmentProcuraduría de la Administración / Gaceta Oficial · Retrieved 2026-09-22 · ES
- TAT-RF-013 of 6 March 2024 — residence criteriaTribunal Administrativo Tributario · Retrieved 2026-09-22 · ES
- Version 8 instructions for individual income returnsDirección General de Ingresos · Retrieved 2026-09-22 · ES
- Treaty and residence-certificate questionsDirección General de Ingresos · Retrieved 2026-09-22 · ES