On 27 May 2019, the Ministry of Economy and Finance of Panama published Executive Decree No. 46 in the official gazette. The decree was issued regarding implementation of country-by-country (CbC) reporting with following requirements:

  • Ultimate parent companies or multinational groups, residents in Panama with consolidated group revenue of EUR 750 million or more, or PAB equivalent as of January 2015, are required to submit CbC report;
  • Must be filed no later than 12 months after the last day of the reporting fiscal year of the MNE group;
  • The reporting entity must annually submit the CbC report in XML Schema and the content of the CbC report is in line with OECD standards
  • MNE groups resident in Panama are required to submit a CbC notification to the Directorate General of Revenue (DGI), including the identity and fiscal residence of the reporting entity, as well as fiscal period of the group;
  • The penalties for failing to comply with the CbC requirements (either CbC reporting or CbC notification) are fines of USD 1,000 to USD 5,000 for the first offense and fines of USD 5,000 to USD 10,000 for repeat offenses.
  • The first fiscal year to be reported is 2018.

The entities may contact with DGI for more information regarding country-by-country reporting requirements. The decree is applicable from 27 May 2019.