After acceptance of the amendment of Article 694 of the Tax Code through Law 120 of 2013 was a huge mistake , the national government enacted last January 10, 2014 in the Official Gazette No. 27450 -A, Act 1 2014 by which Articles 2 and 3 of Act 120 of 2013 is repealed and the effect of Article 694 of the Tax Code is restored .The adopted Law 1 of January 8, 2014 has been enacted as a rule of public policy , repealing sections 2 and 3 of Act 120 of 2013 . In the same text the term of Article 694 is reset prior to its amendment by Act 120 of 2013 , with retroactive effect from December 31, 2013 , to read as follows:Article 694. The object of this tax taxable income that is produced from any source within the territory of the Republic of Panama whatever the place is perceived.Taxpayer is under this title, natural or juridical , domestic or foreign person receiving taxable income subject to the tax .PARAGRAPH 1. Taxable income produced within the territory of the Republic of Panama shall be considered :a. Income from work when staff consists of salaries and other remuneration paid to the State or diplomatic consular representatives or other persons entrusted to carry out functions abroad.b . The staff from paid work salaries, wages , representation expenses or other remuneration in cash or in kind to be paid to employees or contractors by reason of the exercise of their profession or trade .c . The income earned by international shipping companies in the share of freight rates , fares, charges and other services whose origin or final destination in the Republic of Panama , regardless of the place of incorporation or domicile. Income from freight, travel and services to passengers or cargo in transit across the territory of the Republic of Panama are not considered taxable income .Are not considered taxable income produced within the territory of the Republic of Panama revenue from maritime passages and other services when they are earned by operators of cruise ships international companies have their base cruise port or home port in the Republic of Panama .d . All of the net proceeds received from the provision of international telecommunications services , telecommunications companies established in the country .e . Received by natural or legal persons whose domicile is outside the Republic of Panama of any product or service act, documented or not, that benefit individuals or corporations, domestic or foreign, located within the Republic of Panama including, but not limited to fees and income from copyright royalties, key, trademarks or trade , patents , know -how , technological and scientific knowledge , trade secrets , to the extent that such services impinge on the production of income from Panamanian sources or conservation of this and outlay has been considered as expenses deductible by the person who received it .For this, natural or juridical , domestic or foreign, located in the territory of the Republic of Panama to benefit with the service or act concerned shall apply the general tariffs laid down in Articles 699 and 700 of the Tax Code , about fifty percent ( 50 % ) of the amount to be remitted . This duty of withholding will not apply, in the event that a natural or legal person whose domicile is outside the Republic of Panama , is registered as a taxpayer 's income tax to the Directorate General of Revenue.Natural or legal persons who, by reason of their business activities, develop operations outside the national territory that are required for the generation of income declared in the Republic of Panama are not subject to withhold on payments made by those goods and services financed , fully executed contract or outside the country , which are not treated as taxable income .PARAGRAPH 2 . Will not be considered produced in the territory of the Republic of Panama , income from the following activities:a. Invoicing, from an office established in Panama , the sale of goods or products for a greater sum of it for which such goods or products have been billed against office established in Panama where such goods or products only move abroad.b . Directing, from an office established in Panama , transactions are completed, or take effect abroad.c . Dividends or shares of participation of legal entities that do not require notice or Operation does not generate taxable income in Panama , where these come from dividends or income not produced within the territory of the Republic of Panama , including the income from these activities in subparagraphs a. and b . of this Paragraph .The Executive shall establish rules and procedures for determining the portion of total income that is considered taxable income taxpayer who receives taxable income plus exempt referred to in this Paragraph , within a period not exceeding six to income (6 ) months .The Law 1 of January 8, 2014 restored the principle of territoriality and the validity of Article 694 of the Tax Code , therefore only the income produced within Panama is taxed.Paragraph 1 of Article 694 of the Tax Code states what is meant by income produced within Panamanian territory , and highlights the literal e) establishes the treatment applicable to remittances abroad , and that applies to the income received by individuals or legal domiciled outside Panamanian territory , and that you derive from acts or services benefiting persons domiciled in Panamanian territory , which must apply the rates of ISR corresponding to 50% of the amount to send , provided that it has been taken as a deductible expense for the person who received the service.Paragraph 2 of Article 694 says the rents are not considered within Panamanian territory produced by our tax laws , and therefore not be subject to application of ISR .Historical legal institutions such as corporations, banking laws , registration of vessels , the Colon Free Zone , and others are based in these principles.
LEGAL SERVICES; PANAMANIAN CORPORATIONS, PRIVATE INTEREST FOUNDATIONS, IBC FROM BVI, BELIZE,CYPRUS,COSTA RICA, BAHAMAS,SEYCHELLES, ANGUILLA, BARBADOS, AND OTHERS, BANKING LAW, ASSETS PROTECTION AND ADMINISTRATION, INTELLECTUAL PROPERTY, DATA PROTECTION.
miércoles, 22 de enero de 2014
PANAMA RESTORED THE TERRITORIAL PRINCIPLE
After acceptance of the amendment of Article 694 of the Tax Code through Law 120 of 2013 was a huge mistake , the national government enacted last January 10, 2014 in the Official Gazette No. 27450 -A, Act 1 2014 by which Articles 2 and 3 of Act 120 of 2013 is repealed and the effect of Article 694 of the Tax Code is restored .The adopted Law 1 of January 8, 2014 has been enacted as a rule of public policy , repealing sections 2 and 3 of Act 120 of 2013 . In the same text the term of Article 694 is reset prior to its amendment by Act 120 of 2013 , with retroactive effect from December 31, 2013 , to read as follows:Article 694. The object of this tax taxable income that is produced from any source within the territory of the Republic of Panama whatever the place is perceived.Taxpayer is under this title, natural or juridical , domestic or foreign person receiving taxable income subject to the tax .PARAGRAPH 1. Taxable income produced within the territory of the Republic of Panama shall be considered :a. Income from work when staff consists of salaries and other remuneration paid to the State or diplomatic consular representatives or other persons entrusted to carry out functions abroad.b . The staff from paid work salaries, wages , representation expenses or other remuneration in cash or in kind to be paid to employees or contractors by reason of the exercise of their profession or trade .c . The income earned by international shipping companies in the share of freight rates , fares, charges and other services whose origin or final destination in the Republic of Panama , regardless of the place of incorporation or domicile. Income from freight, travel and services to passengers or cargo in transit across the territory of the Republic of Panama are not considered taxable income .Are not considered taxable income produced within the territory of the Republic of Panama revenue from maritime passages and other services when they are earned by operators of cruise ships international companies have their base cruise port or home port in the Republic of Panama .d . All of the net proceeds received from the provision of international telecommunications services , telecommunications companies established in the country .e . Received by natural or legal persons whose domicile is outside the Republic of Panama of any product or service act, documented or not, that benefit individuals or corporations, domestic or foreign, located within the Republic of Panama including, but not limited to fees and income from copyright royalties, key, trademarks or trade , patents , know -how , technological and scientific knowledge , trade secrets , to the extent that such services impinge on the production of income from Panamanian sources or conservation of this and outlay has been considered as expenses deductible by the person who received it .For this, natural or juridical , domestic or foreign, located in the territory of the Republic of Panama to benefit with the service or act concerned shall apply the general tariffs laid down in Articles 699 and 700 of the Tax Code , about fifty percent ( 50 % ) of the amount to be remitted . This duty of withholding will not apply, in the event that a natural or legal person whose domicile is outside the Republic of Panama , is registered as a taxpayer 's income tax to the Directorate General of Revenue.Natural or legal persons who, by reason of their business activities, develop operations outside the national territory that are required for the generation of income declared in the Republic of Panama are not subject to withhold on payments made by those goods and services financed , fully executed contract or outside the country , which are not treated as taxable income .PARAGRAPH 2 . Will not be considered produced in the territory of the Republic of Panama , income from the following activities:a. Invoicing, from an office established in Panama , the sale of goods or products for a greater sum of it for which such goods or products have been billed against office established in Panama where such goods or products only move abroad.b . Directing, from an office established in Panama , transactions are completed, or take effect abroad.c . Dividends or shares of participation of legal entities that do not require notice or Operation does not generate taxable income in Panama , where these come from dividends or income not produced within the territory of the Republic of Panama , including the income from these activities in subparagraphs a. and b . of this Paragraph .The Executive shall establish rules and procedures for determining the portion of total income that is considered taxable income taxpayer who receives taxable income plus exempt referred to in this Paragraph , within a period not exceeding six to income (6 ) months .The Law 1 of January 8, 2014 restored the principle of territoriality and the validity of Article 694 of the Tax Code , therefore only the income produced within Panama is taxed.Paragraph 1 of Article 694 of the Tax Code states what is meant by income produced within Panamanian territory , and highlights the literal e) establishes the treatment applicable to remittances abroad , and that applies to the income received by individuals or legal domiciled outside Panamanian territory , and that you derive from acts or services benefiting persons domiciled in Panamanian territory , which must apply the rates of ISR corresponding to 50% of the amount to send , provided that it has been taken as a deductible expense for the person who received the service.Paragraph 2 of Article 694 says the rents are not considered within Panamanian territory produced by our tax laws , and therefore not be subject to application of ISR .Historical legal institutions such as corporations, banking laws , registration of vessels , the Colon Free Zone , and others are based in these principles.
After acceptance of the amendment of Article 694 of the Tax Code through Law 120 of 2013 was a huge mistake , the national government enacted last January 10, 2014 in the Official Gazette No. 27450 -A, Act 1 2014 by which Articles 2 and 3 of Act 120 of 2013 is repealed and the effect of Article 694 of the Tax Code is restored .The adopted Law 1 of January 8, 2014 has been enacted as a rule of public policy , repealing sections 2 and 3 of Act 120 of 2013 . In the same text the term of Article 694 is reset prior to its amendment by Act 120 of 2013 , with retroactive effect from December 31, 2013 , to read as follows:Article 694. The object of this tax taxable income that is produced from any source within the territory of the Republic of Panama whatever the place is perceived.Taxpayer is under this title, natural or juridical , domestic or foreign person receiving taxable income subject to the tax .PARAGRAPH 1. Taxable income produced within the territory of the Republic of Panama shall be considered :a. Income from work when staff consists of salaries and other remuneration paid to the State or diplomatic consular representatives or other persons entrusted to carry out functions abroad.b . The staff from paid work salaries, wages , representation expenses or other remuneration in cash or in kind to be paid to employees or contractors by reason of the exercise of their profession or trade .c . The income earned by international shipping companies in the share of freight rates , fares, charges and other services whose origin or final destination in the Republic of Panama , regardless of the place of incorporation or domicile. Income from freight, travel and services to passengers or cargo in transit across the territory of the Republic of Panama are not considered taxable income .Are not considered taxable income produced within the territory of the Republic of Panama revenue from maritime passages and other services when they are earned by operators of cruise ships international companies have their base cruise port or home port in the Republic of Panama .d . All of the net proceeds received from the provision of international telecommunications services , telecommunications companies established in the country .e . Received by natural or legal persons whose domicile is outside the Republic of Panama of any product or service act, documented or not, that benefit individuals or corporations, domestic or foreign, located within the Republic of Panama including, but not limited to fees and income from copyright royalties, key, trademarks or trade , patents , know -how , technological and scientific knowledge , trade secrets , to the extent that such services impinge on the production of income from Panamanian sources or conservation of this and outlay has been considered as expenses deductible by the person who received it .For this, natural or juridical , domestic or foreign, located in the territory of the Republic of Panama to benefit with the service or act concerned shall apply the general tariffs laid down in Articles 699 and 700 of the Tax Code , about fifty percent ( 50 % ) of the amount to be remitted . This duty of withholding will not apply, in the event that a natural or legal person whose domicile is outside the Republic of Panama , is registered as a taxpayer 's income tax to the Directorate General of Revenue.Natural or legal persons who, by reason of their business activities, develop operations outside the national territory that are required for the generation of income declared in the Republic of Panama are not subject to withhold on payments made by those goods and services financed , fully executed contract or outside the country , which are not treated as taxable income .PARAGRAPH 2 . Will not be considered produced in the territory of the Republic of Panama , income from the following activities:a. Invoicing, from an office established in Panama , the sale of goods or products for a greater sum of it for which such goods or products have been billed against office established in Panama where such goods or products only move abroad.b . Directing, from an office established in Panama , transactions are completed, or take effect abroad.c . Dividends or shares of participation of legal entities that do not require notice or Operation does not generate taxable income in Panama , where these come from dividends or income not produced within the territory of the Republic of Panama , including the income from these activities in subparagraphs a. and b . of this Paragraph .The Executive shall establish rules and procedures for determining the portion of total income that is considered taxable income taxpayer who receives taxable income plus exempt referred to in this Paragraph , within a period not exceeding six to income (6 ) months .The Law 1 of January 8, 2014 restored the principle of territoriality and the validity of Article 694 of the Tax Code , therefore only the income produced within Panama is taxed.Paragraph 1 of Article 694 of the Tax Code states what is meant by income produced within Panamanian territory , and highlights the literal e) establishes the treatment applicable to remittances abroad , and that applies to the income received by individuals or legal domiciled outside Panamanian territory , and that you derive from acts or services benefiting persons domiciled in Panamanian territory , which must apply the rates of ISR corresponding to 50% of the amount to send , provided that it has been taken as a deductible expense for the person who received the service.Paragraph 2 of Article 694 says the rents are not considered within Panamanian territory produced by our tax laws , and therefore not be subject to application of ISR .Historical legal institutions such as corporations, banking laws , registration of vessels , the Colon Free Zone , and others are based in these principles.
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