Panama Private Interest Foundations

The first complete guide to the Panama Private Interest Foundation after Law 526 rewrote the rules of international tax planning.
>Written by Mauro Savino, an international tax lawyer based in Panama City with a decade spent advising entrepreneurs, high-net-worth families, investors, and internationally mobile clients. This book turns a dense, fast-moving reform into a clear, practical framework you can actually use. No jargon for its own sake. No vague reassurance. Just the rules, the numbers, and the decisions you now have to make.

What you will learn

• How the Panama Private Interest Foundation truly works: charter, regulations, council, founder, protector, beneficiaries, and asset protection
• Why Panama's territorial tax system changed, and what the OECD BEPS framework and Action 5 forced Panama to do
• The three substance conditions every entity must meet to stay exempt: qualified people and infrastructure, strategic decisions taken in Panama, and real local operating costs
• How to outsource substance legally, and what can and cannot be delegated
• Exactly how the new 15% flat tax is calculated, with step-by-step worked examples
• What Law 526 means for United States holders: CFC rules, Subpart F, GILTI, PFIC, and U.S. reporting
• Dedicated chapters for Canadian, Latin American (Peru, Mexico, Argentina, Brazil), and European (Spain, Switzerland, EU ATAD) holders
• Beneficial ownership, the UBO registry, CRS and FATCA reporting, AML/KYC duties, and the tax authority's anti-abuse and disregard powers
• Intellectual property under the modified nexus approach, permanent establishment risks, and Panama's tax treaty network
• A clear before-and-after of the Panama model: the pre-2026 exempt income categories and how the old structure eroded under international pressure
• Compliance in practice: reporting through the income tax return, corporate formalities, and the penalties and enforcement that now apply
• A practical strategic decision matrix: build genuine substance, accept the 15% tax, or restructure, plus transition planning for fiscal year 2027

Who this book is for
This is a practitioner's field manual for the post-Law 526 world, written for tax advisors, lawyers, accountants, wealth managers, family offices, fiduciaries, and the sophisticated individuals and entrepreneurs who depend on Panamanian structures. Whether you manage a single foundation or a portfolio of cross-border vehicles, you will finish with a clear view of your exposure and a concrete plan of action.
Panama did not abolish the foundation. It changed the price of getting it wrong. The advisors who understand the new framework first will protect their clients, win the conversations their competitors cannot, and turn this reform into an advantage.
Understand the new rules before your structure is tested by them.
Scroll up, get your copy today, and move into 2027 with a strategy instead of a surprise.