PANAMA Law and Practice Contributed by: Anna Cristina Valdés, Edgar Herrera, José Manuel Motta and Ramón Arias, Galindo, Arias & López
9. Dispute Prevention 9.1 Advance Pricing Agreements At the time of writing, Panama has not enacted an advance pricing agreement programme. 9.2 Other Mechanisms Since 2024, responses to tax inquiries made by indi - viduals or companies to the Panamanian Tax Authority will be binding only for the tax administration, and only to the extent that they are favourable to the taxpayer making the request. This binding effect is limited to the specific case under consultation and does not extend to future transactions or events that occur after the inquiry.
8.2 Application Deadlines Most of Panama’s double tax treaties containing a MAP clause establish a three-year period from the date of the action giving rise to the dispute to file a MAP request with the Panamanian Tax Authority. 8.3 Mandatory Binding Arbitration While Panama has a functioning MAP process under its double tax treaties, mandatory binding arbitration is not generally available in Panama’s tax treaty net - work.
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