Open Daily: 10am - 10pm | Alley door pickup 10am - 7pm 3038 Hennepin Ave Minneapolis, MN
612-822-4611

  • Open Daily: 10am - 10pm
    Alley-side Pickup: 10am - 7pm

    3038 Hennepin Ave Minneapolis, MN
    612-822-4611

Open Daily: 10am - 10pm | Alley-side Pickup: 10am - 7pm
3038 Hennepin Ave Minneapolis, MN
612-822-4611
Panama Private Interest Foundations: The 2026 Guide to Structure, Substance, and International Tax Exposure Under Law 526 and the New BEPS Framework

Panama Private Interest Foundations: The 2026 Guide to Structure, Substance, and International Tax Exposure Under Law 526 and the New BEPS Framework

Savino, Mauro

Paperback

Investing & Finance

ISBN13: 9798184785677
Publisher: Independently Published
Published: Jun 29 2026
Pages: 134
Weight: 0.42
Height: 0.29 Width: 6.00 Depth: 9.00
Language: English
The first complete guide to the Panama Private Interest Foundation after Law 526 rewrote the rules of international tax planning.
On May 28, 2026, Panama enacted Law 526 and quietly dismantled the assumptions behind decades of offshore structuring. The pure territorial exemption that made Panama famous is gone. Economic substance is now mandatory. And a 15% flat tax awaits every entity that cannot prove it qualifies. If you own, advise on, or are even considering a Panama foundation, the strategy you relied on yesterday may already expose you today.

Written by Mauro Savino, an international tax lawyer based in Panama City with a decade spent advising entrepreneurs, high-net-worth families, investors, and internationally mobile clients. This book turns a dense, fast-moving reform into a clear, practical framework you can actually use. No jargon for its own sake. No vague reassurance. Just the rules, the numbers, and the decisions you now have to make.

What you will learn

  • How the Panama Private Interest Foundation truly works: charter, regulations, council, founder, protector, beneficiaries, and asset protection
  • Why Panama's territorial tax system changed, and what the OECD BEPS framework and Action 5 forced Panama to do
  • The three substance conditions every entity must meet to stay exempt: qualified people and infrastructure, strategic decisions taken in Panama, and real local operating costs
  • How to outsource substance legally, and what can and cannot be delegated
  • Exactly how the new 15% flat tax is calculated, with step-by-step worked examples
  • What Law 526 means for United States holders: CFC rules, Subpart F, GILTI, PFIC, and U.S. reporting
  • Dedicated chapters for Canadian, Latin American (Peru, Mexico, Argentina, Brazil), and European (Spain, Switzerland, EU ATAD) holders
  • Beneficial ownership, the UBO registry, CRS and FATCA reporting, AML/KYC duties, and the tax authority's anti-abuse and disregard powers
  • Intellectual property under the modified nexus approach, permanent establishment risks, and Panama's tax treaty network
  • A clear before-and-after of the Panama model: the pre-2026 exempt income categories and how the old structure eroded under international pressure
  • Compliance in practice: reporting through the income tax return, corporate formalities, and the penalties and enforcement that now apply
  • A practical strategic decision matrix: build genuine substance, accept the 15% tax, or restructure, plus transition planning for fiscal year 2027
Who this book is for

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