Administrative & tax

Tax law

A dispute with the tax authority is rarely won on figures alone. It is won with a well-built file, the right legal grounds and an appeal filed on time. We take on selected tax opinions and appeals, and work with your accountant when the matter calls for accounting work.

Institutional experience: former assistant to a Judge of the Administrative Tax Tribunal.

Matters before the tax authority

Legal work. Accounting is done by your accountant or a specialist, in coordination with us.

01

Tax opinions

Legal analysis of a specific transaction or situation; for example, whether income is Panama-source under the territoriality principle.

02

Information requests and audits

Preparation of responses to information requests, audits and additional assessments, with documentary support for the taxpayer’s position.

03

Appeals before the DGI and the TAT

Requests for reconsideration before the Directorate General of Revenue and appeals before the Administrative Tax Tribunal, where available.

04

Tax penalties

Document-based defence against fines and surcharges.

05

Limitation periods and refunds

Analysis of whether a liability is still enforceable, and applications for refunds or recognition of credits.

Not part of this service

Bookkeeping, preparation of tax returns, transfer pricing studies and comprehensive tax planning. When a matter requires them, we coordinate with your accountant or a specialist, and the proposal says so.

Review before you reply

1

Initial assessment

We review your enquiry, check for conflicts of interest and tell you whether we can take the matter on, what deadlines apply and what is needed.

2

Written proposal

Scope, fees and third-party costs listed separately, plus what is not included. Nothing starts until you accept it.

3

Remote preparation

Documents, filings and strategy are handled by email, video call or messaging, and you review them before anything is filed.

4

Filing and follow-up

Filing with the relevant authority, responses to its requests and progress updates until a decision is issued.

Mostly written work

Tax responses and appeals are written. If any step requires attendance, we identify it during the assessment.

The authorities involved

As a general rule, Panama taxes income produced within its territory: the territoriality principle.

DGI

Directorate General of Revenue

Audits, assesses and collects. It is the first level of almost any national tax dispute.

TAT

Administrative Tax Tribunal

A tribunal independent of the DGI that decides, at the second administrative level, appeals against its decisions.

CSJ

Third Chamber of the Supreme Court

Provides judicial review of decisions taken at the administrative level, through the appropriate claim.

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Municipalities

Local taxes and fees with their own procedure.

What to have ready

For guidance only:

Tax data comes later

Please do not include financial statements or tax ID numbers in the web enquiry. If needed, we will ask for them through an agreed channel.

Worth knowing before you start

When does the time to appeal start running?

Generally from notification of the decision, and it is counted according to the rules of the procedure. Give the notification date in your enquiry so we can check it straight away.

Should I answer a DGI request before getting advice?

It is better to have it reviewed first. A response given without analysis can entrench the authority’s position and narrow the room for a later defence.

Do you keep the books or file tax returns?

No. Our work is legal. When accounting work is needed, it is done by your accountant or a specialist, in coordination with us.

What does the territoriality principle mean?

That, as a general rule, Panama taxes income produced within its territory. Whether a transaction generates Panama-source income is one of the most frequent points of dispute with the authority.

Received a tax request or decision?

Tell us what you received and when you were notified. We will tell you what can be done and what we need to assess it.

Sending an enquiry does not engage the firm or confirm that we will take on the matter.

Other services

This page provides general information about Panamanian law. It is not legal advice and does not replace the analysis of a specific case. Sending an enquiry does not by itself create an attorney-client relationship: an engagement is formalised only by written agreement, after the matter has been assessed and checked for conflicts of interest.