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Panama Publishes Law Introducing BEPS-Compliant Rules for Intangible Assets Income and Re-Impose Certain Transfer Pricing Obligations

08 January 2019

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Approved Changes

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Panama

Panama has published Law No. 69 of 26 December 2018 in the Official Gazette, which entered into force on 28 December 2018 and provides new rules for intangible assets income that are compliant with the modified nexus approach of BEPS Action 5. The Law also includes provisions to re-impose transfer pricing obligations on taxpayers that carry out operations with related parties operating within a preferential regime, including in special economic areas and zones, as well as on taxpayers operating within a preferential regime, even if they are exempt from tax. With respect to the new rules on intangible assets, the...