Panama enacted Executive Decree No. 46 on May 27, 2019, which established the regulatory framework for the Country-by-Country Report.
Country-by-Country Reporting Obligation
The Ultimate Parent Entity of a Multinational Group that, in a tax period, has consolidated revenues exceeding € 750,000,000 or its equivalent in balboas and is a tax resident in Panama must file the Country-by-Country Report annually.
Country-by-Country Report Notification
The Constituent Entity or member of a Multinational Group, which is a tax resident in Panama, will notify the GDT of the tax residence identity of the Reporting Entity and the tax period used by the respective Multinational Group.
Country-by-Country Report Content
- The report must include the amount of revenue, profits, or losses before taxes, income tax paid, income tax accrued, stated capital, retained earnings, number of employees, and tangible assets other than cash or cash equivalents for each jurisdiction in which the Multinational Group operates.
- Identification of each Constituent Entity or member of the Multinational Group and the tax residence jurisdiction of such entity. If the tax residence jurisdiction differs from the tax jurisdiction in which the entity was legally established, the name of the jurisdiction under which the entity was legally established must be reported. The report will also contain the main business activity of such an entity.
- Any additional information or explanation necessary or facilitating the understanding of the information contained in the Country-by-Country Report.
Form and Deadline for Submission
The reporting entity must submit the Country-by-Country Report annually in “XML Schema” format under the regulations and guidelines stated by the GDT within 12 months after the due date of the corresponding tax period.
