This journey assumes
- The US parent is a US corporation that will own the Panamanian company directly.
- The hub will mainly serve group companies outside Panama; it will not sell to the Panamanian retail market.
- The hub will not carry on banking, insurance or other regulated financial services; treasury services will be for group companies only.
- Several US managers will move to Panama and the rest of the team will be hired locally.
- Rules are stated as at 19 October 2026. The SEM regime is stated from Law 41 of 2007 as amended by Law 57 of 2018; later changes were not checked.
If any assumption is wrong for your business, the conclusions change. Ask WONE Global to re-run the analysis with your facts.
Both sides of the border, issue by issue
Each row is one part of the work. The left and right columns show what each country's rules require, so you can see where one side's decision constrains the other.
Investment framework and US reporting
US investment in Panama is protected by the Trade Promotion Agreement in force since 2012, whose investor protections have supplanted those of the 1991 bilateral investment treaty. The two countries exchange tax information under a 2011 agreement but have no income tax treaty. The US parent takes on Form 5471 reporting and possibly BEA surveys.
- The US parent files Form 5471 and its schedules each year for the Panama company to meet the reporting requirements of sections 6038 and 6046.1
- BEA's quarterly BE-577 survey is mandatory for US persons owning 10% or more of a foreign business when BEA contacts them, for affiliates above USD 500 million in assets, sales or net income.2
- The US and Panama exchange tax information on request under a Tax Information Exchange Agreement in force since 2011, covering all national taxes; the IRS can therefore obtain information about the hub.3
- The US-Panama Trade Promotion Agreement, in force since 31 October 2012, protects US companies in Panama against discriminatory or unlawful treatment and provides a neutral process for investment disputes.4
- The 1991 bilateral investment treaty is still listed as in force, but its investor protections have been supplanted by the Trade Promotion Agreement, and the option to use either treaty for older investments ended on 31 October 2022.56
SEM licence, ordinary company or special regime
The hub is normally a Panamanian Sociedad Anonima, which is tax resident in Panama. For a group services hub the key decision is whether to apply for an SEM licence, which limits the company to listed services for its own group in exchange for a 5% tax rate, exemptions and staff visas. Manufacturing-related services have a separate EMMA regime, and goods-holding activities may fit a free zone.
- A Panamanian Sociedad Anonima is a per se corporation for US tax purposes, so the hub is a foreign corporation and, with the US parent owning it, a controlled foreign corporation subject to the anti-deferral rules.78
- Because the hub will serve related companies in other countries, its services and any resale of group products fall within the categories of foreign base company income, which should drive the choice of structure as much as Panamanian tax does.910
- An SEM operates from Panama to provide listed services such as management, logistics, technical assistance, treasury, accounting and IT processing to its own group only.11
- SEM licences are granted by the Technical Secretariat on the recommendation of the Commission for Multinational Headquarters Licences attached to the Ministry of Commerce and Industries.12
- A company incorporated in Panama is tax resident there and must have a resident agent (a Panamanian lawyer or law firm, not confirmed on an official source here).1314
- A separate EMMA licence created by Law 159 of 2020 offers tax, labour and immigration benefits to multinational companies providing manufacturing-related services.15
Tax on both sides, with no treaty
Panama taxes only Panama-source income, at 25% for ordinary companies; an SEM licence holder pays 5% on its net taxable service income and is exempt from dividend tax. That low rate means the US high-tax exception will not apply, so the US parent should expect much of the hub's service income to be taxed currently in the United States as foreign base company income or net CFC tested income.
- There is no US-Panama income tax treaty, so domestic withholding rules apply to payments in both directions.16
- Services performed by the hub for related companies outside Panama are foreign base company services income, and income from buying group products and reselling them outside Panama can be foreign base company sales income.910
- The high-tax exception needs an effective foreign rate above 90% of the US corporate rate, which a 5% SEM rate cannot meet; remaining income is generally included as net CFC tested income from 2026.178
- A 10% US corporate shareholder can generally deduct the foreign-source portion of dividends from the hub under section 245A, so the main US tax cost arises from current inclusions rather than on distribution.18
- Panama taxes Panama-source income at a fixed 25% corporate rate; foreign-source passive income of group entities stays at 0% only if economic substance requirements are met, otherwise 15%.1920
- An SEM licence holder pays 5% on net taxable service income, with a 2% minimum where a foreign tax credit applies, and is exempt from dividend, complementary and branch taxes.2122
- SEM services to foreign group companies without Panama-taxable income are outside ITBMS; services to Panamanian entities and local purchases bear ITBMS at the general 7% rate.2324
- Without an SEM licence, dividends are taxed at 10% (5% from foreign-source or export income), and payments to the US group for services or royalties attract an effective 12.5% withholding, with no treaty relief.2526
Staff, visas and social security
The SEM regime gives the hub its own visa routes for permanent and temporary staff, which is one of its main practical attractions. There is no US-Panama social security agreement, so seconded US staff may face contributions in both systems, and Panamanian payroll carries employer social security and educational insurance.
- Panama is not on the SSA list of countries with US social security agreements, so there is no treaty rule against dual contributions for seconded US staff.27
- US social security tax is 6.2% each for employer and employee on wages up to USD 184,500 in 2026; whether it continues for staff working at the hub depends on how the secondment is structured and should be confirmed.2827
- Law 41 provides an SEM permanent staff visa lasting no longer than the employment contract or five years, and a temporary staff visa for technical or training staff.29
- The National Migration Service grants the SEM temporary staff visa for up to three months, extendable once by three months, on proof of the SEM licence and a company letter describing the engagement.30
- Employers pay 12.25% social security and 1.5% educational insurance on wages with no ceiling; foreign worker quotas under the Labour Code (10% and 15%) apply to ordinary employers and were not confirmed here.3132
Goods, free zones and export controls
If the hub holds regional stock, the Trade Promotion Agreement removed most Panamanian duties on US industrial goods, and Panama's free zones offer exemptions for goods held for re-export. US-origin goods re-exported from Panama remain subject to US export controls.
- Panama is one of the 20 US free trade agreement partners; over 87% of US consumer and industrial exports to Panama became duty-free when the agreement entered into force, with the rest phased out over ten years.334
- US-origin items remain subject to the Export Administration Regulations wherever located, so goods and technology re-exported from a Panama hub must be classified and screened.34
- Entities in Panama's free zones may enjoy exemption from import duties, income tax and sales tax for eligible activities, which can suit stock held for re-export.35
- SEM licence holders must still pay ITBMS on their own imports into Panama.23
Substance, sanctions and bank reporting
Both the SEM licence and Panama's passive income rules depend on real substance in Panama. The US parent must manage OFAC screening for regional counterparties and FBAR reporting for the hub's accounts.
- OFAC sanctions apply to the US parent and its staff; regional counterparties, including in countries subject to US sanctions programmes such as Cuba and Venezuela, must be screened.36
- US persons, including US officers who sign on the hub's Panamanian accounts, must check FBAR filing where foreign accounts exceed USD 10,000 in aggregate during the year.37
- SEM licence holders must meet substance criteria set by the licensing commission, including a minimum number of full-time employees and annual operating expenses in Panama.38
- Group entities earning foreign-source dividends, interest or royalties keep the 0% rate only with economic substance, otherwise 15% applies.20
Structures to consider
These are the structures businesses commonly weigh, not a recommendation. The right one depends on the facts listed under "What we need from you".
What has to happen first
- United StatesUS board approves the hub, its services and the group entities it will serve.
- United StatesModel US tax on the hub (foreign base company income, net CFC tested income, section 245A) against Panamanian options before choosing a regime.After step 1
- Both sidesDecide between an SEM licence, an ordinary company and a free-zone or EMMA vehicle.After step 2
- PanamaIncorporate the Panamanian Sociedad Anonima through a resident agent and register it for tax.After step 3
- PanamaApply to the Ministry of Commerce and Industries for the SEM licence with a substance plan (employees and operating expenses).After step 4
- United StatesSet up Form 5471, FBAR and any BEA reporting in the US group.After step 4
- Both sidesOpen bank accounts and fund the hub; screen regional counterparties against OFAC lists.After step 4
- Both sidesSign intercompany services agreements with each group company served, with transfer pricing that works for the US and each recipient country.After step 3
- Both sidesObtain SEM permanent or temporary staff visas for US and other foreign managers, and settle their social security position.After step 5
- PanamaHire local staff, register with the CSS and lease premises to meet the substance commitments.After step 5
- PanamaStart services; charge ITBMS only where services go to Panamanian entities.After step 7, 8, 9, 10
- Both sidesOngoing: Panamanian returns and SEM substance reporting; US Form 5471, foreign base company income and net CFC tested income each year.After step 11
What we need from you before anyone can advise
- Which services the hub will provide, to which group companies and in which countries.
- Whether the hub will hold stock, act as a buy-sell distributor or provide any manufacturing-related services.
- Whether any income will come from third parties or from Panama-source activities.
- Planned headcount and operating spend in Panama (SEM substance).
- Number of US and other foreign staff to move, their nationalities and assignment length.
- Group consolidated revenue and existing BEA reporter status.
- Whether any group companies served are in countries subject to US sanctions programmes.
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Panama market records in the knowledge base hold no source-checked claims; all Panamanian points here were researched afresh, and most tax points rely on PwC Worldwide Tax Summaries.
- The SEM regime is stated from Law 41 of 2007 and Law 57 of 2018; later amendments, current SEM regulations, numeric substance thresholds and MICI licensing procedure were not checked.
- The resident agent requirement, company incorporation procedure, beneficial ownership register and the Panamá Emprende notice of operation were not confirmed on official sources.
- Labour Code foreign worker quotas, MITRADEL work permits and whether they apply to SEM staff were not confirmed.
- Panama's transfer pricing rules, the economic substance law behind the 15% passive income rate, and any domestic minimum top-up tax were not confirmed.
- Panama's use of the US dollar, absence of exchange controls and bank onboarding expectations were not source-checked.
- Colón Free Zone, Panama Pacífico and EMMA conditions could not yet be checked in their own laws.
- The TIEA entry-into-force date is taken from the Treasury announcement of 18 April 2011; the agreement text could not yet be checked.
- Whether Panama is on any EU or other list affecting payments from group companies in other countries was not checked.
Brief for your advisers
Questions to put to your advisers in each country. Copy them, or download them as a text file to send with your requirement.
- US tax adviser: how much of the hub's income will be foreign base company services or sales income or net CFC tested income, and does an SEM licence change the US result at all?
- Panamanian tax adviser: do our planned services qualify for an SEM licence, and what substance will the commission expect?
- Panamanian tax adviser: what tax applies to income from any services outside the SEM list or to third parties?
- Both tax advisers: how should intercompany service fees be priced and documented so that the US, Panama and each recipient country accept them, given that there is no US-Panama treaty?
- Panamanian corporate adviser: what does incorporation require, including the resident agent and beneficial ownership records?
- Immigration adviser: which SEM visa suits each manager, how long does it last, and what is the current procedure and fee?
- Employment and payroll advisers: what CSS and other contributions apply to our staff, and how do we avoid double social security contributions for US staff?
- Trade adviser: if we hold stock in Panama, should it sit in a free zone, and what export control screening do re-exports need?
Who can help, on each side
United States
- Contracts and commercial law · Led by F Miles Adler
- Accounting and annual filings · Arranged by WONE Global on request
- Disputes and arbitration · Arranged by WONE Global on request
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Tax and structuring · Led by F Miles Adler
- Employment, payroll and immigration · Arranged by WONE Global on request
- Customs, trade and export controls · Arranged by WONE Global on request
- Anti-bribery, sanctions and compliance · Arranged by WONE Global on request
Panama
- Contracts and commercial law · Led by Ebrahim Asvat K.
- Accounting and annual filings · Arranged by WONE Global on request
- Disputes and arbitration · Arranged by WONE Global on request
- Setting up and running a company · Arranged by WONE Global on request
- Licences, permits and regulators · Arranged by WONE Global on request
- Tax and structuring · Led by Ebrahim Asvat K.
- Employment, payroll and immigration · Arranged by WONE Global on request
- Customs, trade and export controls · Arranged by WONE Global on request
- Anti-bribery, sanctions and compliance · Arranged by WONE Global on request
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Certain US persons who are officers, directors or shareholders of certain foreign corporations must file Form 5471 and its schedules to meet the reporting requirements of sections 6038 and 6046 of the Internal Revenue Code. Federal. Current instructions are dated December 2025 (page updated 17 September 2026). The filer categories that apply to a US parent corporation are set out in the instructions, which could not yet be checked in full.
BEA's quarterly survey of US direct investment abroad (BE-577) is mandatory for each US person with a direct or indirect 10% or more voting interest in a foreign business enterprise, for directly owned affiliates whose total assets, annual sales or net income exceeded USD 500 million, with reports due 30 days after each quarter (45 days for the final quarter). Federal. Only US persons contacted individually by BEA must report. Indirectly owned affiliates are reportable where they meet the USD 500 million test and have intercompany balances with the US reporter above USD 10 million. Other BEA outward surveys (BE-10, BE-11) were not checked.
A US-Panama Tax Information Exchange Agreement, signed on 30 November 2010, entered into force in April 2011, allowing each country to request information on all national taxes in civil and criminal matters for tax years beginning on or after 30 November 2007. Bilateral. The agreement covers information exchange only and does not reduce tax rates.
Archived Treasury press release; the effective date is the announcement date and the exact entry-into-force date in the agreement was not checked.
The US-Panama Trade Promotion Agreement entered into force on 31 October 2012; it protects US companies in Panama against discriminatory or unlawful treatment and provides a neutral, transparent process for investment disputes. Bilateral. Panama's services commitments under the agreement go further than its WTO commitments, including financial, distribution, express delivery and professional services.
The Panama-United States bilateral investment treaty, signed on 27 October 1982, entered into force on 30 May 1991 and is listed as in force; an amending protocol entered into force on 14 May 2001. Bilateral. The treaty may be terminated on one year's notice, with a ten-year survival clause.
The page lists two dates under status without labels; signature and entry into force are read in order.
The US International Trade Administration states that the investor protection provisions of the US-Panama Trade Promotion Agreement have supplanted those of the 1991 bilateral investment treaty, while investments made under the treaty kept the option to use dispute settlement under either agreement until 31 October 2022. Bilateral.
Page last published 27 March 2026.
US entity classification regulations list the Panamanian Sociedad Anonima as a per se corporation, always treated as a corporation for US federal tax purposes. Federal, 26 CFR 301.7701-2(b)(8)(i). Entity forms not on the list may be eligible entities that can choose their classification.
Regulation text reproduced by Cornell LII; the eCFR original could not yet be checked.
For taxable years beginning after 31 December 2025, each United States shareholder of a controlled foreign corporation must include its net CFC tested income in gross income; Public Law 119-21 renamed this inclusion from global intangible low-taxed income (GILTI). Federal, 26 USC 951A as amended by Pub. L. 119-21, section 70323. Applies to US shareholders (generally 10% owners) of controlled foreign corporations.
Foreign base company services income of a controlled foreign corporation includes income from technical, managerial, engineering and similar services performed for or on behalf of a related person outside the country under whose laws the corporation is organised. Federal, 26 USC 954(e)(1). A Panama hub serving group companies in other countries is the typical case.
Foreign base company sales income includes income from buying personal property from, or selling it to or for, a related person where the property is made outside the controlled foreign corporation's country of organisation and sold for use outside that country. Federal, 26 USC 954(d)(1). Relevant if the Panama company buys group products and resells them to other countries.
Law 41 of 2007 defines a Multinational Company Headquarters (SEM) as a company that operates from Panama to provide listed services, such as management, logistics, technical assistance, treasury, accounting and IT processing, to its own corporate group only. Arts. 3, 4 and 6. Other services may be approved by the Cabinet Council.
Original 2007 text as published in the Gaceta Oficial; later amendments other than Law 57 of 2018 were not checked.
SEM licences are granted by the Technical Secretariat after a recommendation from the Commission for Multinational Headquarters Licences, an advisory body attached to the Ministry of Commerce and Industries (MICI). Law 41 of 2007, arts. 9 and 11.
Original 2007 text as published in the Gaceta Oficial; later amendments other than Law 57 of 2018 were not checked.
A company incorporated in Panama is tax resident there, and residence also arises where Panama is the place of central management; Panama follows the OECD permanent establishment rules. Panamanian income tax.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
Every Panamanian company must have a resident agent who is a lawyer or law firm licensed in Panama. Corporate law. Not confirmed on an official source.
Research draft: no official page was opened to confirm the rule or its legal basis.
Law 159 of 31 August 2020 created a special regime for the establishment and operation of multinational companies providing manufacturing-related services (EMMA licence), with tax, labour and immigration benefits. Conditions and the exact benefits were not stated in the source.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point. The source describes it as a special regime for multinational companies; the manufacturing-services scope reflects its name and should be confirmed.
The IRS list of the United States income tax treaties does not include Panama, so there is no US-Panama income tax treaty. Comprehensive income tax treaties listed by the IRS as at October 2026. Without a treaty, US and Panama domestic withholding rates apply in full to cross-border dividends, interest, royalties and service fees.
Income is excluded from foreign base company income only if it was subject to foreign income tax at an effective rate greater than 90% of the maximum US corporate rate in section 11. Federal, 26 USC 954(b)(4). With the 21% federal rate this means an effective foreign rate above 18.9%.
The 18.9% figure is arithmetic from the 21% rate in IRS Publication 542, not a figure stated on the page.
A domestic corporation that is a United States shareholder of a specified 10-percent owned foreign corporation may deduct the foreign-source portion of dividends received from it. Federal, 26 USC 245A(a). Does not apply to hybrid dividends (245A(e)), where the foreign company obtained a deduction or other tax benefit for the payment. Holding period and foreign tax credit interactions could not yet be checked.
Panama taxes income on a territorial basis: income sourced in Panama is taxable, and corporations pay income tax at a fixed rate of 25%. Panamanian income tax. An alternative calculation (CAIR) on 4.67% of gross taxable income can apply where taxable income exceeds USD 1.5 million.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
Panamanian entities of multinational groups that earn foreign-source passive income such as dividends, interest or royalties keep a 0% rate only if they meet economic substance requirements; otherwise that income is taxed at 15%. Panamanian income tax; the substance tests and legal basis were not stated in the source.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
SEM licence holders pay income tax at 5% of net taxable income from their services, and where a foreign tax credit applies they must still pay at least 2% of the net taxable income generated in Panama. Law 57 of 2018, art. 5 (amending art. 21 of Law 41 of 2007), effective 1 January 2019. Credits cannot be carried forward or refunded. Holders with legal stability under Law 54 of 1998 kept their exemption until it expires.
SEM licence holders are exempt from the dividend tax, the complementary tax and the branch tax, whether their income is local, foreign or exempt. Law 57 of 2018, art. 7 (new art. 21-B of Law 41 of 2007).
Services provided by an SEM to persons domiciled abroad that have no Panama-taxable income are not subject to ITBMS, but services to entities with operations in Panama are, and the SEM remains liable for ITBMS on its own purchases and imports in Panama. Law 41 of 2007, art. 22 and paragraph. Whether art. 22 was later amended was not checked.
Original 2007 text as published in the Gaceta Oficial; later amendments other than Law 57 of 2018 were not checked.
Panama's ITBMS (VAT) is charged at a general rate of 7%. Higher rates apply to alcoholic beverages and hotel accommodation (10%) and tobacco (15%).
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
Panamanian-source dividends are subject to a final 10% withholding when distributed; dividends paid out of foreign-source, export or certain exempt income are taxed at 5%, and dividends on bearer shares at 20%. Applies to ordinary Panamanian companies; SEM licence holders are exempt (see the Law 57 claim). A complementary tax applies where less than 40% of net profits is distributed.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
Panama-source payments to non-residents for services and royalties are taxed at 25% on 50% of the remittance, an effective 12.5%, and Panama's tax treaty list does not include the United States. Panamanian withholding. If the payer chooses not to withhold, the expense is not deductible. Interest on loans invested in Panama is taxed on the same 50% basis.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
The Social Security Administration's list of countries with which the United States has social security (totalization) agreements does not include Panama. Without an agreement in force there is no treaty rule to prevent the same earnings being subject to both US and Panamanian social security contributions.
The page carries a certification date of 25 November 2019 but lists agreements entering into force as late as 1 September 2026, so it is maintained.
For 2026, social security tax is 6.2% each for employer and employee on wages up to a wage base limit of $184,500. Federal (FICA). Wages above the wage base are not subject to social security tax.
Law 41 of 2007 provides a permanent staff visa for SEM personnel, for a term that cannot exceed the employment contract or five years, and a temporary staff visa of up to three months for technical or training staff. Arts. 26 to 28 of the original law.
Original 2007 text as published in the Gaceta Oficial; later amendments other than Law 57 of 2018 were not checked.
The National Migration Service grants a temporary staff visa for foreigners providing technical services to licensed SEM headquarters for up to three months, extendable once for a further three months, on proof of the SEM licence and a company letter describing the contract. Article 149-D of the migration regulations (Executive Decree 320 of 2008).
Undated requirements sheet; fees listed in it (USD 250 and USD 800 cheques) should be confirmed before application.
Employers in Panama pay social security (CSS) contributions of 12.25% and educational insurance of 1.5% on wages, with no maximum taxable amount. Employer rates; a 2025 social security reform may change pension contributions in stages and was not confirmed.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
The Labour Code limits foreign workers to 10% of an employer's ordinary staff and 15% of its specialist or technical staff, subject to permits from the Ministry of Labour (MITRADEL). Labour Code art. 17. SEM and other special regimes may have their own rules. Not confirmed on an official source.
Research draft: a 2017 MITRADEL statistics sheet lists permit categories "Dentro del 10%" and "Excedente del 15%", but the Labour Code text could not yet be checked.
The United States has comprehensive free trade agreements in force with 20 countries: Australia, Bahrain, Canada, Chile, Colombia, Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, Israel, Jordan, Korea, Mexico, Morocco, Nicaragua, Oman, Panama, Peru and Singapore. Federal. Japan is covered by separate limited agreements (including a critical minerals agreement) that USTR does not count as free trade agreements.
CBP's free trade agreements page lists the same 14 agreements.
Items subject to the Export Administration Regulations include all items in the United States, all US-origin items wherever located, certain foreign-made items incorporating controlled US-origin content above de minimis levels and certain foreign-produced direct products, and items subject to the EAR but not listed on the Commerce Control List are designated EAR99. Federal, 15 CFR 734.3(a) and (c), administered by the Bureau of Industry and Security. Whether a licence is needed depends on the item's classification, destination, end user and end use. Defence articles under ITAR are outside this claim.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.
Entities in Panama's free zones may enjoy exemption from import duties on goods, income tax and sales tax, among other taxes, for eligible business types. Exemptions depend on the zone and the regime; the Colón Free Zone and Panama Pacífico have their own laws, not yet checked.
Secondary source (last reviewed 4 August 2026); the Panamanian Fiscal Code and DGI pages could not yet be checked for this point.
The Office of Foreign Assets Control (OFAC), part of the US Treasury, administers and enforces US economic and trade sanctions, using asset blocking and trade restrictions against targeted countries, regimes and persons. Federal. Programmes include Russia-related, Iran, North Korea, Cuba, Venezuela-related, counter-narcotics and cyber-related sanctions.
A US person, including a corporation, partnership or LLC, with a financial interest in or signature authority over foreign financial accounts whose combined value exceeds 10,000 US dollars at any time in the calendar year must file FinCEN Form 114 (FBAR) electronically, due 15 April of the following year with an automatic extension to 15 October. Federal. Applies to a US subsidiary that holds accounts abroad, for example with its foreign parent's bank.
SEM licence holders must meet substance requirements set by the Commission for SEM Licences, whose criteria include a minimum number of full-time employees and annual operating expenses in Panama suited to the business. Law 57 of 2018, art. 3 (amending art. 12 of Law 41). Existing holders had until 30 June 2021 to comply. The law sets no numeric thresholds.
