Panama’s General Revenue Directorate (DGI) has strengthened its oversight of related-party transactions by adopting Version 3.0 of Form 930, which corresponds to the Transfer Pricing Local File that required taxpayers must file. The change, now implemented in the e-Tax 2.0 system, incorporates new reporting requirements that require corporate groups with a presence in Panama to review in advance how they document their intercompany transactions.
Beyond a change in format, the update reflects a regional trend: tax authorities continue to strengthen their control mechanisms through more detailed reports, with structured information that facilitates risk analysis and data cross-checking during audit processes.
The Regulation and Its Effective Date
Through Resolution No. 201-4247 of June 16, 2026, published in the Official Gazette on July 1, 2026, the General Revenue Directorate formally adopted version 3.0 of Form 930, applicable to returns for the 2026 tax year and subsequent years. Furthermore, the DGI confirmed through its official channels that the form is now available in the e-Tax 2.0 system for filing.
Taxpayers who still need to file information for the 2025 tax year or earlier will continue to use the previous version of the form; therefore, both versions will coexist during the transition period.
Three new schedules increase the level of detail required
Version 3.0 includes three schedules that were not present in the previous form and significantly increase the level of detail required by the tax administration.
Financial Information Schedule
Specific financial information from the income statement and balance sheet corresponding to the analyzed party must be reported, broken down by each type of Transfer Pricing analysis performed.
Related Party Information Annex
The main change is that it will no longer be sufficient to simply identify the counterparty to the transaction. Now, the nature of the relationship, the physical address of the related party, and the name of its legal representative must also be reported, thereby strengthening the identification of each entity involved in the reported transactions.
Appendix on Fixed Assets
Where applicable, the following information must be provided: a description of the asset, its condition, the depreciation method used, its estimated useful life, and the address where it is physically located.
Operational Considerations
According to official information available at the time of this publication, the DGI has not yet released the technical instructions for version 3.0 of Form 930, which will provide details on each of the new fields included.
In the meantime, taxpayers should consider the following aspects:
- Filing continues to be done exclusively through the e-Tax 2.0 system.
- The report must be filed within six months following the end of the tax period.
- All amounts must be expressed in U.S. dollars.
- Form 930 retains two important rules that remain in effect: it does not allow for filing extensions or amended returns. If an error is detected within the legal deadline, the taxpayer must request the cancellation of the submitted return by means of a duly substantiated letter signed by the legal representative, subject to the DGI’s approval, and then file a new return.
- Failure to comply with this obligation may result in the penalties provided for in Article 762-I of the Panamanian Tax Code, with fines of up to B/.1,000,000, depending on the circumstances of the case.
The adoption of Version 3.0 of Form 930 confirms a trend we have been consistently observing in Latin America: tax authorities continue to evolve toward increasingly structured reporting frameworks, incorporating specific information that could previously be supported by supplementary documentation but must now be expressly disclosed within the official forms.
The inclusion of annexes on financial information, related parties, and fixed assets demonstrates the DGI’s interest in strengthening its risk analysis mechanisms and facilitating the cross-referencing of information from different sources. Consequently, business groups must ensure not only the availability of Transfer Pricing documentation but also the consistency, quality, and traceability of all information used to complete Form 930.
Furthermore, given that the form does not allow for extensions or amended returns, advance preparation takes on strategic importance. A preliminary review of financial, corporate, and operational information will help reduce the risk of inconsistencies that could lead to subsequent requests for additional information or tax audits.
At TPC Group, we assist corporate groups with operations in Panama and throughout Latin America in complying with their transfer pricing obligations, from the identification and documentation of intercompany transactions to the preparation of the technical study supporting each filing. Our specialized team assesses the impact of regulatory changes in each jurisdiction, enabling us to anticipate necessary adjustments, enhance the quality of reported information, and reduce the risks associated with potential tax audits.
Source: