Bill 641, introduced by the Ministry of Economy and Finance on April 30, 2026, amends and adds articles to the Fiscal Code on the subject of income tax and establishes economic substance requirements for certain foreign-source passive income. According to the legislative record, the initiative reached the stage of Ley.

The text provides that certain foreign-source passive income obtained by entities belonging to multinational groups must be backed by real economic activity in the national territory in order to maintain their tax treatment. The explanatory memorandum holds that global standards require that tax benefits be grounded in genuine economic activity.

The measure aims to align Panama's tax regime with the practices promoted by international bodies on transparency and taxation of multinational groups. For the corporate services sector, the change offers a clearer criterion regarding the conditions an entity must meet to retain incentives associated with foreign-source income.

The precise scope of the new obligations will depend on its regulatory implementation. Nexo Capital will follow the publication of the final text in the Official Gazette and the guidelines issued by the tax administration.