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Panama Introduces New Withholding Tax Form for Amended Multinational Enterprises Headquarters Regime

19 February 2025

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Approved Changes

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Panama

Panama's Ministry of Finance has issued Resolution No. 201-1394 of 5 February 2025, which approves withholding tax Form No. 1119 (v:1). The form is to be used for the withholding tax introduced by Law No. 57 of 24 October 2018 on certain payments made to and by companies under the Multinational Enterprises Headquarters regime (Sedes de Empresas Multinacionales - SEM). Law No. 57 introduced several amendments to improve the SEM regime and to comply with BEPS Action 5 (Harmful Tax Practices). Among other things, this included the introduction of a 5% income tax for SEM companies on net income derived...