Panama Cross-Border Tax.
Panama-side cross-border tax planning under the territorial principle: source-of-income analysis, pre-arrival positioning, holding architecture, and special regimes.
Source-of-income analysis
Determining what is Panama-source vs. foreign-source under the territorial principle, and what therefore falls outside Panamanian taxation.
Economic substance analysis
Testing group structures against Panama's economic substance law, which reaches multinational-group entities receiving foreign-source passive income without real substance, and carries a final 15% tax on that income from the 2027 tax year.
Pre-arrival tax planning
Timing of relocation, asset titling, and account structuring before establishing Panamanian tax residency.
Holding-company tax planning
Structuring Sociedades Anónimas and Private Interest Foundations to hold operating, real-estate, and investment assets across borders.
Operating-company tax planning
Permanent-establishment analysis, dividend and royalty flows, and steady-state compliance for Panamanian operating companies.
Multinational Headquarters (SEM) regime
Reduced corporate income tax, expat-employee benefits, and qualifying-activity analysis under Law 41.
Free-zone & special regimes
Panama Pacifico, Colon Free Zone, City of Knowledge, and EMMA regimes for logistics, technology, and manufacturing operators.
Continue across Cross-Border Tax
US Cross-Border Tax
US-side cross-border tax planning across ECI, FDAP, PE, CFC, and PFIC regimes, plus estate, trust, and pre-immigration positioning for globally mobile clients.
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Canada Cross-Border Tax
Canada-side cross-border tax planning: residency cessation, deemed-disposition planning, FAPI, trust taxation, and the information-reporting regime.
Read sectionMalta Cross-Border Tax
Malta-side planning for individuals establishing residence under Maltese programmes, with treaty access to both the United States and Canada.
Read sectionBarbados Cross-Border Tax
Barbados-side planning under the remittance basis, with treaty access to both the United States and Canada.
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In closing
Let’s talk.
A single conversation usually clarifies more than a month of research. We engage on a value basis, and every introduction begins with a direct, confidential exchange.
We advise on
- Cross-Border Tax
- International Corporate Advisory
- Multi-jurisdictional Asset Structuring
- Panama Relocation
Rothbard Group S.A.
A boutique cross-border tax and corporate advisory firm. Licensed U.S. Enrolled Agent authorized to practice before the Internal Revenue Service.