A company is considered as a tax resident when it has been incorporated in Panama and if Panama is regarded as the place where the central management is located. Entities incorporated abroad may also be registered with the tax administration in order to avoid WHT.
Permanent establishment (PE)
Panama follows the Organisation for Economic Co-operation and Development (OECD) PE rules.
The income referable to a PE or fixed place of business is the income obtained by the PE, as if it was an independent or different entity, taking into consideration the activities developed, assets used, and risks assumed.