Panama Golden Visa: Qualified Investor Guide

Legal notice, scope and currency

See also the overview of Decree 17 for the changes that matter before choosing a route.

SCOPE AND DATE This English edition adapts the German legal commentary dated 22 September 2026. Statements concerning Executive Decree 17/2026 were checked against the official Spanish text on 27 October 2026, including tables, checklists and diagrams. This editorial check is not a new personal approval by the author or a complete update of every employment, tax or passport issue. The decree of 8 September 2026 was published and entered into force on 16 September 2026. The original Spanish legislation, the forms and checklists applicable to the individual application, and case-specific assessment remain decisive. Unpublished administrative practice is not presented as settled law.

This white paper provides general information about Panama’s residence subcategory Residente Permanente en calidad de Inversionista Calificado. Golden Visa is an international communication term, not a separate statutory title, and must not be confused with citizenship by investment.

This document is neither an individual legal opinion nor a promise of approval, processing time, bank acceptance, investment returns, property value, work permission, tax status or naturalisation. The Servicio Nacional de Migración (SNM), Ministerio de Comercio e Industrias (MICI), and the relevant supervisory, registry and financial institutions make their own assessments.

The investment amounts are qualifying capital, not government fees. Additional legal, notarial, apostille, translation, banking, trustee, registry, due-diligence, travel, property-transfer and custody costs depend on the case. The tax, civil-law and regulatory consequences of an investment must be assessed separately from residence eligibility.

The scope is limited to general information on Panamanian law. Tax, company, succession, family, social-security, reporting and nationality law in the applicant’s home country or any other jurisdiction require appropriately qualified advisers in that jurisdiction.

About the author

Karen Dorcy, LL.M., is an attorney admitted in Panama (Idoneidad No. 10179). She has practised since 2011, focusing on Panamanian immigration, residence, property and company law. She completed her LL.M. at Leibniz University Hannover and advises in German, Spanish and English. [P29], [P30]

APPROACH The commentary follows the legal assessment sequence: legal basis → eligibility conditions → evidence → investment and compliance checks → procedure → continuing obligations → risks.

Methodology and source hierarchy

The research primarily uses the Spanish originals. Statements are classified by source level. Where official websites simplify the law or lag behind an amendment, the published legislation takes precedence. Administrative guidance is identified as guidance rather than legislation.

Table 1 · Source hierarchy and evidential weight

References such as [P35, Art. 8] point to the source register in Appendix H and, where possible, a specific provision. Historical versions explain the programme’s development or transitional cases. The current framework is Executive Decree 17/2026; Decree 722/2020 and its amendments are no longer the complete governing text for new cases.

Three labels distinguish the strength of a statement: LEGAL POSITION identifies a proposition supported by primary law or an official publication. OFFICIAL GUIDANCE identifies an administrative summary. PRACTICAL CHECK identifies a matter requiring written confirmation before an irreversible payment or filing because the published framework does not conclusively resolve the detail.

SOURCE RULE An official landing page is useful but does not replace the Official Gazette or an assessment of applicable transitional and amending provisions.

How to use this white paper

1. For the initial decision: executive summary and Chapters 3, 15 and 17.

2. For property investors: Chapters 4, 7, 10 and 11, and Appendix C.

3. For securities or fixed-deposit investors: Chapter 5 or 6, Chapter 7 and Appendix D.

4. For a specific application: Chapters 8–11 and the evidence maps in Appendix B.

5. Before accepting an engagement: address the practical checks in Appendices G and L for the individual case.

Four concepts to keep separate from the outset

ASSESSMENT RULE For every proposition, distinguish legislation, official procedural guidance, statistics and legal planning. Its source determines how confidently it can be stated.

Executive summary: seventeen key propositions

Table 2 · Golden Visa in seventeen propositions

LEGAL CONCLUSION The appropriate route is the one whose ownership, payment trail, risk structure and five-year maintenance can be reliably evidenced—not simply the route with the lowest threshold.

Primary sources for this section: [P35, Arts. 1–21], [P5], [P6, Arts. 28, 31 and 34], [P21].

1 · Legal nature and classification

1.1 Official category and market terminology

Executive Decree 722 of 15 October 2020 created the subcategory Residente Permanente en calidad de Inversionista Calificado. Executive Decree 17/2026 has governed it since 16 September 2026, replacing the original decree and its amendments. Status remains permanent from the first approval; a temporary or provisional preliminary stage is not an eligibility requirement. [P35, Arts. 1 and 20–21]

Golden Visa is a familiar search term, but it can obscure three distinctions: this is not an entry-visa label, citizenship by investment or an entitlement arising solely from owning assets. Residence approval and investment assessment are connected but remain decisions of the competent authorities.

1.2 Seven distinct statuses and forms of evidence

Table 3 · Keep these separate

CLARIFICATION A residence permit does not authorise regulated professions, certify tax residence or replace bank KYC.

Primary sources for this section: [P35, Arts. 1, 11, 15–16 and 20–21], [P5], [P6, Arts. 28, 31 and 34], [P8], [P18]–[P21].

2 · Development of the programme: 2020–2026

Since 16 September 2026 the framework has been Executive Decree 17/2026, which fully replaces Decree 722/2020 and its 2022 and 2024 amendments. Earlier texts remain relevant to legislative history and expressly protected transitional cases, but are not the current complete framework for new applications. [P35, Arts. 18–21]

Table 4 · Legislative chronology

2.1 Substantive changes under Executive Decree 17/2026

• The property route distinguishes qualifying new, unoccupied first sales and development purchases from other property. The former start at B/.300,000; other or secondary-market property generally requires B/.500,000.

• For registered property, the qualifying value is the lower of the price actually paid and the evidenced market value, less real encumbrances. Financing may cover the excess above the applicable minimum where it is documented and traceable and does not reduce the qualifying net value below the minimum. [P35, Art. 5]

• Development purchases may use a licensed trust. Alternatively, full payment to the developer requires an irrevocable, unconditional bank instrument payable on first demand covering the entire investment paid.

• Market fluctuations not attributable to the investor do not alone constitute a breach if there is no voluntary withdrawal, disposal or encumbrance and the minimum is restored within 90 calendar days after MICI notification (Article 8).

• Fixed deposits qualify from B/.500,000 at Banco Nacional de Panamá or Caja de Ahorros and B/.750,000 at a private bank with a General License. Annual evidence and investment changes are governed by distinct notification and replacement periods.

EDITORIAL RULE Decree 17/2026 is the controlling replacement text. The MICI portal reviewed for the German edition still referred to Decree 722 and earlier undifferentiated thresholds. An administrative summary does not override the Gazette.

2.2 Transitional rules and relevant dates

Applications filed before entry into force generally retain the requirements, conditions and amounts applicable when filed, while more favourable procedural rules may apply immediately. Existing investments and binding contracts perfected before entry into force may use the previous regime if the application is filed within six months from entry into force. Existing certificates remain effective until expiry. Article 18 provides a twelve-month conversion opportunity for pending applications or valid status under Solvencia Económica Propia, subject to the new requirements; investments predating 15 October 2020 are excluded from that conversion. [P35, Arts. 18–19]

TRANSITION CHECK Do not mix old and new requirements. Record the regime relied on, the dated facts supporting transitional treatment and the deadline for the complete application.

2.3 Law 493/2025: travel-document framework, not a new residence product

Law 493 of 28 October 2025 amended Law 32/2013 on Panama’s Passport Authority. It entered into force on 29 October 2025 and addresses a special passport or travel document for certain foreign residents, including qualified investors and dependants recognised by SNM. It does not alter Decree 17/2026 investment thresholds or permanent-residence eligibility. [P21], [P34], [P35]

The distinction is essential: the document does not replace the ordinary passport of nationality and does not confer Panamanian nationality. The document-specific minimum investment, procedure and fees require implementing rules. Law 493 instructed the executive to regulate within six months of promulgation. Expiry of that period does not itself make issuance operational. The German source review did not verify an implementing decree, form, fee schedule and receiving office; current availability requires separate confirmation. [P21], [P34]

PUBLICATION STANDARD Do not advertise an immediately available Panamanian passport or citizenship by investment on the strength of this framework. Establish the operative regulation, application channel, form and fees before making an availability statement. A statutory instruction to regulate is not evidence of actual issuance.

Sources for this section: [P1]–[P5], [P13], [P21], [P34], [P35]; implementation research in the German source edition dated 22 September 2026.

3 · Comparing the three investment routes

TERMINOLOGY The three asset classes—property, securities and fixed deposits—comprise five legal structures: completed property, development purchase by promise contract, securities, deposits at Banco Nacional or Caja de Ahorros, and deposits at a private bank with a General License. Thresholds, evidence and failure risks differ.

Table 5 · Decision overview

The minimum amount alone is not a sound selection criterion. Consider the source and availability of funds, risk capacity, ownership structure, annual evidence and whether a later change can comply with residence-maintenance rules.

3.1 Four questions before choosing a route

1. Can the entire chain from the foreign origin of wealth to the Panamanian receiving account be evidenced?

2. Who is the legal owner, account holder and ultimate beneficial owner?

How will the investment be maintained for five years, evidenced in the 30-day window before each immigration-resolution anniversary, and replaced in compliance with the applicable notification and replacement rules?

4. What non-immigration risks arise from the project, market, bank, tax, succession, divorce or creditor claims?

3.2 Do not select solely by minimum amount

Table 6 · Qualitative decision matrix

Document the route decision in two stages. First, establish whether its immigration requirements can be evidenced. Then independently assess economic, tax and civil-law implications and suitability for the client’s risk profile. Immigration eligibility is not an investment recommendation.

Primary sources for this section: [P35, Arts. 2–9].

4 · Property route from B/.300,000 or B/.500,000

The property route distinguishes qualifying first sales and development purchases from other property. B/.300,000 is sufficient only for a qualifying new, unoccupied first-sale property or qualifying purchase promise. Other property, particularly previously used or resold property, generally requires B/.500,000. [P35, Arts. 4–6]

4.1 Registered property

A qualifying new, unoccupied first-sale property requires at least B/.300,000; other property generally requires B/.500,000. Use the lower of the price actually paid and evidenced market value, less real encumbrances. The excess above the minimum may be financed if the financing is documented and traceable and does not reduce qualifying net value below the threshold. Assess aggregation and allocation of individual properties before payment. [P35, Arts. 4–6]

Table 7 · Core evidence for registered property

4.2 Purchase promise with a trust

For a qualifying new, unoccupied first-sale property under a purchase promise from B/.300,000, capital may be deposited in a trust administered by a bank or trust company licensed in Panama. The purchase promise, trust deed, payment schedule and disbursement mechanism must evidence the entire qualifying investment and contractual project obligations. [P35, Arts. 4–7]

A trust does not automatically eliminate development or insolvency risk. Review disbursement conditions, refunds, information rights, construction milestones, fees, termination and any replacement investment needed for residence purposes.

4.3 Full payment secured by a bank instrument

Decree 17/2026 also allows full direct payment to the developer before construction, segregation or registration is complete. An irrevocable, unconditional bank instrument payable on first demand must secure the investor’s entire investment paid. [P35, Art. 7]; [P13]

• The secured amount must cover at least the entire investment paid.

• Keep the bank instrument effective until construction, segregation and registration in the investor’s name; renew and submit it to MICI annually.

• Annual renewal and submission until transfer of title is complete.

• Annual submission to MICI as part of investment-maintenance evidence.

• The investor, not MICI, is the beneficiary.

• Treat assignment, contractual changes or termination of the purchase promise as potential investment changes and notify MICI within the applicable period.

• The instrument must be callable for the prescribed developer-attributable failures to complete or perfect the purchase promise. Its terms must reflect the statutory triggers.

4.4 Developer default, 180 working days and the three-year limit

Where a purchase promise is not perfected on time for a reason attributable to the developer, the replacement period is 180 working days from the first working day after the contractual deadline. It does not start when a guarantee pays out. Replacement with another purchase promise is allowed only once. If that replacement also fails, a completed eligible investment is required. Status may rely solely on purchase promises for no more than three years in aggregate. General notification and maintenance obligations also apply. [P35, Arts. 7 and 12]

4.5 First-sale status, payment and market value

The qualifying property value is the lower of the price actually paid and evidenced market value, less real encumbrances. The B/.300,000 threshold also requires qualifying first-sale and non-occupation status. An ANATI certificate does not replace payment evidence or market-value verification. Where an independent valuation is required, Article 6 governs its currency, professional qualifications and independence. [P35, Arts. 4–6]; [P16], [P17]

Table 8 · Reconcile value and payment before closing

PRACTICAL CHECK If the lower of the price actually paid and evidenced market value, after deducting real encumbrances, is below B/.300,000 or B/.500,000, the property does not meet the relevant threshold. Before closing, reconcile the valuation method, valuer qualifications, first-sale status and non-occupation with MICI certification requirements.

4.6 Reviewing the bank instrument: amount alone is insufficient

SBP-DJ-CIRCULAR-2025-0075 and its guarantee model addressed Decree 722 as amended in 2024. Decree 17/2026 requires an irrevocable, unconditional bank instrument payable on first demand. Review the actual instrument against the current decree rather than relying uncritically on an earlier model. Amount, demand period, documentary conditions, renewal, governing law, jurisdiction, fees and the issuing bank’s credit quality require separate assessment. [P13], [P35]

• Reconcile the original instrument wording with the contract and immigration file before payment.

• Assign responsibility and escalation dates for timely renewal and continued coverage.

• Avoid milestone disbursements that leave actual exposure outside the security coverage.

• Test demand events using the actual documents and deadlines, not only an abstract description.

• If the bank or development encounters problems, prepare investment replacement and immigration notifications in parallel.

DEVELOPMENT RISK A purchase promise’s immigration eligibility does not replace technical, financial, title and insolvency due diligence on the development.

Primary sources for this section: [P35, Arts. 4–7], [P13], [P16], [P17].

5 · Securities route from B/.500,000

Article 8 permits one or more qualifying securities investments totalling at least B/.500,000 through an SMV-licensed Casa de Valores, personally or through a legal entity of which the applicant is the absolute ultimate beneficial owner. Eligible categories include the specified funds, Panamanian government debt and qualifying corporate instruments with economic activity in Panama. Registration and supervision must be evidenced for each instrument; the custodian must document any exemption for government-issued or guaranteed securities or other exempt instruments. Maintain the investment continuously for five years from its perfection. [P35, Art. 8]

5.1 Three institutional checks

1. Intermediary: Is the brokerage currently licensed, not suspended, and authorised for the proposed product?

2. Issuer/instrument: Is the instrument registered with SMV or validly exempt, and does it meet the decree’s Panama-related requirements?

3. Custody: Who holds the instruments, and can holdings, value and encumbrance/maintenance status be clearly certified each year?

Table 9 · Core securities-route evidence

5.2 Market movements and portfolio changes

Market fluctuations not attributable to the investor do not by themselves breach the minimum where no voluntary withdrawal, disposal or encumbrance occurs and the minimum is restored within 90 calendar days after MICI notification. Voluntary withdrawals, transfers and encumbrances are subject to the general maintenance rules. [P35, Arts. 8 and 12]

Table 10 · Events during the five-year period

5.3 Independent checks before placing an order

1. Record the brokerage’s SMV status on the order date and retain evidence.

2. Establish registration or an applicable exemption for each instrument and the required connection to Panama.

3. Obtain written confirmation that annual certificates can identify investor, instruments, quantity, invested amount, custodian and encumbrances.

4. Test maturity, termination rights and corporate actions against the applicable notification/replacement rules and five-year calendar.

5. Authorise the order only after immigration assessment and independent investment review.

KEEP SEPARATE A security that qualifies for immigration purposes is not necessarily suitable, safe, liquid or profitable. Investment advice is a separate assessment.

Primary sources for this section: [P35, Arts. 8 and 12], [P14], [P15].

6 · Fixed-deposit route from B/.500,000 or B/.750,000

A fixed deposit requires at least B/.500,000 at Banco Nacional de Panamá or Caja de Ahorros, or B/.750,000 at a private bank with a General License. It must remain in place for at least five calendar years, free of encumbrances, blocking arrangements, third-party financing and pledges. Foreign source of funds is mandatory for both routes. Article 9 does not establish a general B/.200,000 minimum per account. [P35, Art. 9]

Table 11 · Bank evidence and contract review

6.1 Interest and reinvestment

Separate interest from qualifying capital. Payment, capitalisation or transfers must not undermine the minimum or absence of encumbrances. Notify changes or cessation during the commitment period within 30 calendar days; MICI generally grants up to 90 calendar days to evidence a compliant replacement investment. [P35, Arts. 9 and 12]

6.2 Bank KYC is a separate acceptance process

The decree does not require any bank to accept a client. Banks apply risk-based due diligence. Wealth creation, tax status, occupation or business, beneficial ownership, transaction purpose and the source of a particular transfer may require evidence beyond the immigration checklist. [P11], [P12], [P24]

6.3 The role of SBP circulars

Circular SBP-DJ-0017-2022 addressed the earlier fixed-deposit immigration certificate. Circular SBP-DJ-0043-2022 addressed investment and international-transfer information; SBP-DJ-0075-2025 updated certification and the guarantee model following Decree 193/2024. They provide historical documentary and supervisory context, but must be reconciled with Decree 17/2026, particularly the state-bank route and prescribed bank security. [P11]–[P13], [P35]

Table 12 · Agree bank-certificate content in advance

6.4 Banking compliance: separate from visa eligibility

The banking prevention framework, including the SBP instruments cited below, is not a separate investor-visa category. It governs risk-based customer and beneficial-owner identification, risk classification, differentiated due diligence, monitoring and governance. A complete immigration dossier may therefore still lead to additional bank questions or rejection. Confirm the operative banking rules and institutional requirements when onboarding. [P24], [P25]

SEQUENCE Bank pre-clearance and agreed certificate wording should precede an irreversible capital commitment.

Primary sources for this section: [P35, Arts. 9 and 11–12], [P11]–[P13], [P23]–[P25].

7 · Source of funds, payment trail and beneficial ownership

The minimum investment must come from the applicant’s own funds of foreign origin. Gifts and other gratuitous third-party transfers do not satisfy it. Funds already in Panama’s financial system may be recognised where their earlier international transfer, attribution to the applicant and use for the investment are evidenced. There is no general foreign-source exemption for state-bank deposits or government debt; Article 9 expressly requires foreign source for both deposit routes. [P35, Arts. 2–3, 9 and 11]; [P11]

7.1 Three evidence layers

Table 13 · Source of wealth, source of funds and transfer trail

7.2 Investing through an entity

Personal and entity-held investments are possible. Evidence existence, representation, beneficial ownership, effective control and allocation of the investment. Article 3 expressly addresses private-interest foundations. There is no blanket requirement for 100% share ownership across every route. Authenticate foreign entity documents and translate them into Spanish where required. Stricter route-specific requirements, particularly Article 8 for securities, remain applicable. [P35, Arts. 2–3, 5 and 8]

7.3 Joint ownership

Article 3 expressly addresses co-ownership, joint holdings and companies or private-interest foundations with multiple beneficial owners. Each principal applicant must individually meet the minimum. A joint investment may count for a principal applicant and spouse or dependants in the same application if their co-ownership or beneficial entitlement and the required net value are evidenced. [P35, Art. 3(6)]

7.4 Evidence trails for common sources of wealth

Table 14 · Source-of-wealth evidence map

7.5 The funds-flow memorandum

For complex cases, a folder of bank statements is insufficient. A funds-flow memorandum records the date, amount, currency, sending account, holder, intermediary bank, receiving account, economic purpose and evidence reference for each transfer. Explain exchange conversions, charges and instalments so that MICI, SNM and the financial institution can reconstruct the same facts from the same evidence.

1. Prepare a source-of-wealth narrative with a timeline and economic background.

2. Trace the actual investment funds through the originating account back to their source.

3. Explain every intermediary and account holder; assess third-party payments before accepting them.

4. Identify foreign-language core documents consistently and prepare them for translation.

5. Keep the banking and immigration versions consistent in facts and amounts.

PRACTICAL RISK Gifts and gratuitous third-party transfers are excluded from satisfying the minimum investment by Article 2. Other complex funding trails—crypto-asset proceeds, cash-related transactions, multiple intermediary accounts or differing holders—require a separate eligibility and evidence assessment and may create significant acceptance risk.

Primary sources for this section: [P35, Arts. 2–3 and 11], [P11]–[P13], [P23]–[P25].

8 · Personal application dossier

Article 11 of Decree 17/2026 incorporates the common requirements of Article 28 of Decree Law 3/2008, except its paragraph 4, and adds programme-specific evidence and payments. Personal criminal-record and sworn-declaration requirements must be assessed for each adult applicant. The dossier combines general documents, programme documents and route-specific investment evidence. Transitional cases also require relevant investment and filing dates. [P35, Arts. 11 and 18–19]; [P6]

Table 15 · Principal applicant’s core dossier

8.1 Foreign documents

Foreign documents must meet Panama’s authentication requirements. An apostille generally applies between Hague Convention parties; otherwise consular legalisation may be required. Non-Spanish documents require an accepted Spanish translation. Review the original, authentication, translation and name variations as one evidence chain.

8.2 Do not assume a universal validity period

Document validity may depend on legislation, the checklist, issuing country and administrative requirements. This guide does not apply a blanket six-month rule to every document. Confirm the current submission window before obtaining time-sensitive documents.

8.3 Obtaining documents abroad: German-speaking examples

Table 16 · Examples from Germany, Austria and Switzerland

This table retains the German source’s country examples; it is not a checklist for the United States, Canada, the United Kingdom or every other jurisdiction. The issuing and authenticating authority depends on document type and local government structure. Before ordering, prepare a matrix of issuer, authentication authority, full-form requirement, name spelling and filing deadline. Verify current instructions in the issuing country.

8.4 Name and date reconciliation

International records may use diacritics, compound names, academic titles, former surnames and different transliterations. Before authentication, reconcile passport name, birth name, parents’ names, birthplace, date of birth, marriage details and spelling in every document. Resolve discrepancies before filing.

DOCUMENT RULE Approve the required form and naming consistency first; then obtain, authenticate and translate the document. Translation cannot cure an unsuitable certificate or incorrect apostille.

Primary sources for this section: [P35, Art. 11 together with D.L. 3/2008 Art. 28], [P6], [P7]; confirm foreign-document requirements with the relevant issuing and authentication authorities.

9 · Spouses, children, parents and other dependants

Assess each dependant against the applicable personal requirements. Article 17 allows a principal investor who maintains status and investment to add children subsequently born or adopted and a spouse married after the original approval. Required evidence includes the relationship documents, current MICI investment certification and B/.1,000 to the Treasury plus B/.1,000 to SNM per dependant. Article 17 does not automatically extend this mechanism to the spouse and children of an adult dependant who later marries. [P35, Arts. 11 and 17]

LIMIT OF THE STATEMENT The MICI summary identifies categories of family members but is not a complete definition of age, study and dependency conditions. Confirm adult-child and parent requirements against the current SNM/MICI checklist rather than treating a general portal statement as sufficient.

Table 17 · Family evidence map

Children born or adopted later and a new spouse of the principal investor may be added directly under Article 17 if the requirements are evidenced. Death, divorce, reaching adulthood and other changes must be reported. Continued status of dependants requires an individual, reasoned decision and an opportunity to be heard; a change does not automatically cancel residence. [P35, Article 17]

9.1 Adult children

General Panamanian immigration rules and published filing summaries commonly require children aged 18–25 to study full time, remain financially dependent and be unmarried. The current MICI programme page does not detail all these conditions. Confirm the special office’s applicable checklist and evidence standard before filing. A simple enrolment certificate without evidence of the intensity of study, or a general maintenance declaration, may be insufficient. [P5]–[P7]

9.2 Parents

MICI expressly lists parents as potential beneficiaries, provided they qualify (“que califiquen”). Its public page does not comprehensively explain the required evidence of financial dependency, age, household or maintenance. Before structuring the investment, establish whether the parents qualify as dependants or would need their own principal applications or another residence category.

9.3 Fees per dependant

Article 11 of Executive Decree 17/2026 specifies B/.1,000 payable to the National Treasury and B/.1,000 to SNM as a repatriation deposit for each dependant. Some practice summaries describe different treatment of the second amount for minors. Confirm the actual payment instructions in writing for each person and age group immediately before filing. This guide budgets the full statutory amount and does not promise an exemption. [P35, Article 11]

FAMILY CHECK Keep a separate eligibility, civil-record, fee and status-consequence entry for each person. Inclusion in an application does not mean exemption from documents or costs.

Primary sources for this section: [P35, Articles 11 and 17], [P6], [P7].

10 · Procedure: from initial assessment to residence card

10.1 Procedure

Table 18 · Ten stages

10.2 Filing before entry

Article 16 allows filing before entering Panama through a representative holding a specific power of attorney. Biometric registration (filiación) and registration in the foreigners’ register must be completed before receiving an immigration card; this provision does not make them prerequisites for filing. It does not promise a wholly travel-free process. [P35, Article 16]

10.3 The 15- and 30-working-day rules

MICI has a maximum of 15 working days from admission of a complete file. If deficiencies are notified, the applicant has 15 working days from notification to remedy them; MICI’s decision period begins only once the deficiencies are fully remedied. SNM has a maximum of 30 working days from formal receipt of the complete file, subject to lawful suspensions. These are not overall deadlines including preparation and card issuance. [P35, Article 15]

10.4 Distinguish MICI certification from SNM approval

The MICI investment certificate and SNM residence decision are separate legal acts. The certificate is valid for three months and must be valid when the complete SNM application is filed. Expiry afterwards does not alone require renewal if the delay is not attributable to the applicant. Article 7 does not establish a general five-working-day response obligation. [P35, Articles 3 and 15]; [P5]

Table 19 · Authority and record

10.5 Personal attendance, RUEX and cédula

Article 16 permits filing before entry. Biometric and foreigners’ registration must be completed before an immigration card is issued. Any further cédula formalities must be coordinated separately under current SNM and Tribunal Electoral instructions. RUEX, an immigration card, a cédula and a residence resolution are different documents and procedures. [P35, Article 16], [P26], [P27], [P33]

10.6 Requests, refusal and remedies

Decree Law 3/2008 provides the general immigration procedure framework; Executive Decree 17/2026 establishes the special deadlines in Article 15. Requests for additional evidence and decisions refusing or cancelling residence require prompt assessment of response deadlines and available remedies. The applicable appeal, time limit and any suspensive effect must be checked against the actual decision and administrative procedure law. This guide does not prescribe a universal appeal deadline. [P6, Article 34]; [P27]; [P35, Article 15]

RESPONSE RULE Record, translate and legally assess every notification on receipt; assign a deadline and responsible person. An informal email is not a substitute for a formally compliant submission.

PLANNING FORMULA Total time = document collection + KYC/investment + MICI certification + SNM review + registration/card. The 15- and 30-working-day periods start only when the respective completeness requirements in the decree are met; they do not represent total elapsed time.

Sources for this section: [P35, Articles 3, 11 and 13–16], [P5], [P6, Articles 28 and 34], [P26], [P27], [P33].

11 · Five-year maintenance and annual evidence

The investment must be maintained for at least five years. Annual evidence must be filed with MICI within the 30 calendar days before the anniversary of the immigration resolution. The MICI certificate date does not determine this deadline. Before disposing of the investment after year five, check that the minimum maintenance period, annual evidence and any outstanding changes have been fully addressed. [P35, Article 12]

Table 20 · Maintenance calendar

11.1 Changing or replacing the investment

A change or cessation of the investment must be reported to MICI within 30 calendar days. MICI grants up to 90 calendar days to evidence a compliant replacement investment; the related cancellation procedure is suspended during that period. Article 12 does not provide an automatic additional 90-day force-majeure extension. For market fluctuations not attributable to the investor, the restoration period runs from MICI notification (Article 8). For developer-attributable project delay, the special 180-working-day period starts on the first working day after the contractual deadline (Article 7). [P35, Articles 7–8 and 12]

Table 21 · Annual evidence by investment route

11.2 Annual evidence protocol

1. Set reminders 120, 90 and 60 days before the immigration resolution anniversary; schedule filing within the statutory 30-calendar-day window immediately preceding it.

2. Request an institutional confirmation with current wording aligned with Executive Decree 17/2026.

3. Reconcile ownership, personal, contractual and product changes since the previous year.

4. File with MICI within the statutory window and retain an auditable receipt.

5. Track onward transmission to SNM or official confirmation where available.

6. Escalate discrepancies before the underlying transaction rather than trying to explain them retrospectively.

11.3 Absence and residence maintenance

Article 31(3) of Decree Law 3/2008 identifies absence exceeding two years as a ground for cancellation of permanent residence unless justified and authorised by the SNM Director. MICI’s advice to visit once every two years is a practical summary, not a substitute for the statutory exception or a guarantee against other cancellation grounds. [P5], [P6]

NO UNIVERSAL 24-HOUR RULE The law refers to absence exceeding two years and possible authorisation. It does not prescribe a universal minimum visit of 24 hours.

Sources for this section: [P35, Articles 7–8 and 12], [P5], [P6, Article 31(3)].

12 · Employment, self-employment and regulated professions

Permanent residence and permission to work are separate. Executive Decree 6/2023 generally requires a valid MITRADEL work permit for employment, while providing exceptions for certain independent economic, business or investment activities without an employment relationship of subordination. The actual activity determines the classification. [P8]

12.1 Type 4B work permit

Category 4B covers permanent residents under the Qualified Investor programme. Common requirements include registration, a notarised power of attorney, an application through counsel, immigration status certification, and passport and residence-card evidence. For renewals, Article 77 additionally requires an income-tax return and tax clearance (paz y salvo), or evidence of nine social-security contributions. [P8], [P9]

Table 22 · Work-permit essentials

MITRADEL’s page labels B/.250 as the card cost (costo del carné) and B/.30 as card renewal (renovación del carné). It does not clearly describe B/.250 as the general fee for every initial and renewal decision, or B/.30 as a duplicate-card fee only. This guide preserves that distinction; obtain current payment instructions or a cost breakdown before budgeting. [P9], [P10]

12.2 Regulated professions

A work permit does not override nationality restrictions, professional suitability requirements (idoneidad) or sector-specific licences. The Constitution allows statutory restrictions reserving certain professions to Panamanian nationals. Assess the intended activity under the relevant professional and sector rules. [P20]

Primary sources for this section: [P8, particularly Article 77], [P9], [P10], [P20, Article 40].

13 · Tax residence and territorial taxation

Investor residence does not automatically determine tax residence. Article 762-N of the Fiscal Code provides alternative connections for individuals based on days present and a permanent home established in Panama. A tax residence certificate (Certificado de Residencia Fiscal) involves a separate DGI procedure and evidence standard. [P18], [P19], [P31]

Table 23 · Four separate tax questions

The investment itself may trigger tax consequences: property and transfer taxes, interest or securities income, company obligations, withholding taxes, inheritance and succession issues, and reporting in the previous country of tax residence. Assess these before deciding to invest.

13.1 Territorial taxation: Article 694 is the starting point

Article 694 of the Fiscal Code defines and extends Panamanian-source income for different income categories. It does not support a blanket statement that all foreign receipts are tax-free. Relevant factors include the activity, where services are performed or used, the debtor, contractual and payment arrangements, and category-specific rules. Law 33/2010 amended parts of Article 694; use the Fiscal Code as consolidated at the date of advice. [P22]

13.2 Tax residence under Article 762-N

Article 762-N provides alternative connections for individuals: presence exceeding 183 days, continuously or intermittently, in a tax year or the immediately preceding year; or a permanent home (vivienda permanente) established in Panama. Executive Decree 958/2013 and DGI resolutions address evidence and tax residence certification. An immigration residence resolution replaces neither the legal assessment nor the certificate. Limited presence in Panama also does not automatically end tax residence in another country. [P18], [P31]

13.3 A tax residence certificate requires evidence

DGI’s FAQ describes applications through e-Tax 2.0 and an approximate processing time of three months, rather than a guaranteed deadline. For individuals, the listed evidence includes an application letter, a complete notarised passport copy, immigration movements, ownership or rental evidence, utility records and other connections. The application relates to a particular year and, where relevant, a particular treaty purpose. Confirm the current checklist when applying. [P19]

13.4 International and treaty review

DGI distinguishes treaties that are negotiated, signed, ratified and in force. Do not assume that a negotiated or signed treaty already provides relief. For applicants from any country—including the United States, Canada, the United Kingdom, Germany, Austria and Switzerland—verify whether an applicable treaty is in force and whether the person and income qualify. Residence, any tie-breaker, entitlement to benefits and the income category require separate analysis. The German source guide uses the DACH countries as examples; its conclusions should not be transferred automatically to other countries. [P32]

TAX CHECK Before investing or relocating, obtain coordinated advice in Panama and the relevant other jurisdiction on tax residence, income source, exit tax, controlled-foreign-company rules, investment income, property and company consequences, reporting and succession.

COMMUNICATION RULE “Panama taxes on a territorial basis” is not a complete tax analysis. Income must be classified by source, activity, contractual arrangements and where services are performed.

Sources for this section: [P18], [P19], [P22, amendments to Article 694 of the Fiscal Code], [P31], [P32].

14 · Naturalisation as a separate procedure

Article 14 of Executive Decree 17/2026 provides for qualified investors and their dependants to apply for naturalisation after five consecutive years of residence, subject to the Constitution. MICI certifies maintenance of the investment; the application is submitted to MICI’s Investment Directorate and is subject to SNM review of the constitutional and statutory requirements. It does not grant automatic citizenship or entitlement based solely on investment. Family changes are governed by Article 17. [P20, Article 10]; [P35, Articles 14 and 17]

Neither Executive Decree 17/2026 nor the investment amount grants nationality. The five-year investment maintenance period is not automatically identical to residence qualifying for naturalisation. Continuity of residence, actual circumstances, absences, procedure and consequences in the applicant’s existing nationality jurisdiction require separate analysis.

Table 24 · No automatic progression

14.1 The constitutional five-year requirement

Article 10(1) of the Constitution includes five consecutive years of residence, a declaration of intent to naturalise, express renunciation of the previous nationality, Spanish-language knowledge and basic knowledge of Panama’s geography, history and political organisation. Article 14 of Executive Decree 17/2026 provides an application channel involving MICI certification; it does not waive the constitutional conditions, grant automatic nationality or guarantee processing time. [P20, Article 10]; [P35, Article 14]

14.2 The special passport under Law 493/2025

Table 25 · Residence, special passport and nationality

STRICT WORDING RULE Do not describe the programme as buying a passport, an immediate Panamanian passport, full citizenship or guaranteed visa-free travel. Expiry of the statutory implementation period in April 2026 does not itself make the special document available. Before advising on the special passport, verify the implementing rules, competent authority, travel-document recognition, fees and validity through official sources.

Sources for this section: [P20, Article 10 and applicable naturalisation provisions], [P21], [P34], [P35, Article 14 on the separate naturalisation procedure].

15 · Planning time and costs

15.1 Core government amounts

Table 26 · Official amounts, excluding private costs

The repatriation deposit is distinct from an application fee or freely available advance payment. Executive Decree 17/2026 retains the amounts but does not set out a comprehensive refund process for every situation. Confirm refund eligibility, offsets, triggering events and the current administrative procedure in writing before budgeting. Private professional and third-party costs should be itemised separately in an individual quotation. [P35, Article 11]

15.2 Actual project time, rather than advertised time

Table 27 · Realistic time components

KEEP PROMISES The statutory periods do not guarantee a card within 30 days. MICI: maximum 15 working days from admission of the complete file. SNM: maximum 30 working days from formal receipt of the complete file, subject to lawful suspensions. The complete project includes additional stages.

15.3 Programme activity

SNM’s provisional statistics for January–September 2026 record 323 approved residence permits in the Qualified Investor category, as at 30 September 2026. This is an activity indicator, not an approval rate: the published overview does not provide a complete denominator of submitted, withdrawn, pending and refused applications or break the category down by investment route. [P28]

READING THE STATISTICS The figure of 323 refers to approved permits in the category in the provisional overview for January–September 2026, as at 30 September 2026. It is not an approval percentage or a count of all cases, principal investors or investments. It demonstrates neither a guaranteed 30-day process nor investment quality.

Primary sources for this section: [P35, Articles 11 and 15], [P9], [P10], [P28].

16 · Risk matrix and common mistakes

Table 28 · Assess risk before marketing claims

16.1 Seven costly mistakes

1. Completing the investment before aligning bank, MICI and immigration evidence.

2. Treating the purchase price as the qualifying value without applying the lower of the amount actually paid and market value, deducting encumbrances and proving the relevant first-sale status under Executive Decree 17/2026.

3. Using a company or private foundation without establishing the required beneficial ownership, control and funds trail. Obtain specific legal clarification for any structure outside the express rules.

4. Relying on a brochure, reservation agreement or private promise instead of the statutory security for a purchase promise.

5. Buying securities before verifying the intermediary’s licence and the securities’ registration or lawful exemption.

6. Pledging the deposit or structuring it so that fees reduce the qualifying capital below the minimum.

7. Failing to manage maintenance, absences, family changes and work-permit requirements after approval.

16.2 Responding to refusal or cancellation risk

Table 29 · Escalation protocol

Article 12 governs the minimum maintenance period, notification, replacement investment and annual evidence. Failure to make a required replacement within the granted period risks cancellation of residence. The general cancellation grounds in Decree Law 3/2008 also apply. Article 12 does not contain a separate catalogue of immediate cancellation grounds. Remedies and deadlines depend on the actual decision and applicable procedure. [P35, Article 12]; [P6, Articles 31 and 34]; [P27]

Primary sources for this section: [P35, Articles 7–8, 12 and 18–19], [P6, Articles 31 and 34], [P8], [P11]–[P15], [P21], [P27].

17 · When each route fits—and when none does

Table 30 · Qualitative route selection

17.1 Considering alternatives

If the capital commitment, documentation or risk profile does not fit, another Panamanian residence category may be more appropriate. Compare legal conditions, stages, work rights, family inclusion, evidence duration, actual life plans and total costs—not just the lowest investment amount.

Table 31 · Initial category screening, not detailed advice on alternatives

This table does not replace the separate Friendly Nations and Pensionado guides. It supports initial eligibility screening before capital is committed.

ACCEPTING AN ENGAGEMENT An investment should not be recommended solely because it qualifies for residence. Its investment rationale and immigration purpose must each withstand separate assessment.

18 · Six case studies

The following are fictional, simplified planning examples. They contain no client information and do not replace legal, investment or tax advice.

Case A · Resale property with bank financing

An applicant buys a previously occupied property for B/.450,000. B/.300,000 comes from sale proceeds in Germany, with B/.150,000 financed by a bank.

ANALYSIS Insufficient under Executive Decree 17/2026. Resale and other property generally require B/.500,000; the B/.300,000 threshold is reserved for qualifying new, previously unoccupied first-sale or project property. Financing may cover the excess over the applicable minimum only if documented and traceable, and the qualifying net value remains above the threshold.

Case B · Direct payment for a new development

A married couple pays B/.320,000 in full to the developer for qualifying new, previously unoccupied first-sale property. The unit has not yet been separately registered.

ANALYSIS In principle, only with the prescribed irrevocable, unconditional first-demand bank instrument covering the entire amount paid, full payment evidence and project due diligence. For developer-attributable delay, the 180-working-day replacement period begins on the first working day after the contractual deadline. Only one replacement with another purchase promise is permitted; status based solely on purchase promises may not exceed three years in total.

Case C · Securities portfolio

An entrepreneur plans to invest B/.500,000 of dividend income in several Panamanian securities issues.

ANALYSIS Before purchase, verify the securities house’s licence, instrument eligibility, SMV registration or documented exemption, custody and annual evidence. Dividend resolutions, tax and bank records, and the international transfer trail establish wealth creation and source of funds.

Case D · Deposit intended as collateral

A family plans a B/.750,000 deposit at a private general-licence bank and intends to use it later as collateral for a loan.

ANALYSIS A pledge conflicts with the requirement that the deposit remain unencumbered. A qualifying deposit at Banco Nacional de Panamá or Caja de Ahorros may instead start at B/.500,000, but pledging it is equally impermissible. Banking and liquidity requirements need separate assessment.

Case E · Investment through a holding structure

The applicant plans to hold property through a Panamanian company or private foundation. Funds originate from a European holding company in which the applicant has an indirect interest.

ANALYSIS A company or private foundation may qualify if beneficial ownership, effective control, individual allocation, representation, transfers and source of wealth are fully evidenced. Article 3 expressly includes private foundations. Obtain legal review before payment.

Case F · Special passport as the sole objective

A prospective applicant will invest only if the special passport contemplated by the 2025 law is issued within 30 days.

ANALYSIS Do not structure the engagement on that condition. Residence approval and the special passport are separate. The SNM working-day deadline does not guarantee a passport or nationality. Expiry of the statutory implementation period does not itself establish an operational issuing procedure. Obtain official confirmation of the implementing rules and actual availability before giving advice on that document.

Primary sources for this section: fictional examples based on [P35], [P11]–[P15].

19 · Frequently asked questions

19.1 Is “Golden Visa” the official name?

No. The official status is Residente Permanente en calidad de Inversionista Calificado. “Golden Visa” is a marketing and search term.

19.2 Does the programme grant direct permanent residence?

On approval, yes: there is no preliminary two-year temporary residence stage within this programme. Approval remains an individual governmental decision.

19.3 What are the minimum investments under Decree 17/2026?

B/.300,000 for qualifying new, previously unoccupied first-sale or project property; generally B/.500,000 for other property; B/.500,000 for qualifying securities; B/.500,000 for a deposit at Banco Nacional de Panamá or Caja de Ahorros; and B/.750,000 for a deposit at a private general-licence bank.

19.4 Does B/.300,000 apply to every property?

No. Executive Decree 17/2026 limits that threshold to qualifying new, previously unoccupied first sales and regulated project purchases. Other property, including resale property, generally requires B/.500,000. The qualifying value is also the lower of the price actually paid and evidenced market value, less real encumbrances.

19.5 Are there three or more investment routes?

There are three economic asset classes but five legal structures: completed property acquisition, project purchase through a purchase promise, securities, deposits at the two specified state banks, and deposits at private general-licence banks.

19.6 Can I finance the excess property price?

The amount exceeding the minimum may be financed if the financing is documented and traceable and encumbrances do not reduce the qualifying net value below the threshold. The relevant value is the lower of the price actually paid and evidenced market value, less real encumbrances. [P35, Article 5]

19.7 Can I use a development project?

Yes, through an eligible trust or 100% payment to the developer with the required first-demand bank instrument. For developer-attributable delay, the 180-working-day period begins on the first working day after the contractual deadline. Only one replacement with another purchase promise is allowed; status based solely on purchase promises may not exceed three cumulative years. [P35, Article 7]

19.8 Can I freely rebalance a securities portfolio?

No. For market fluctuations not attributable to the investor, restore the minimum within 90 calendar days after MICI notification; there must be no voluntary withdrawal, disposal or encumbrance. Voluntary changes remain subject to the general maintenance and replacement rules. [P35, Articles 8 and 12]

19.9 Can I borrow against the deposit?

No. The deposit must remain unencumbered. A pledge or other security interest jeopardises eligibility.

19.10 Must the money come from abroad?

Yes. Evidence own foreign-source funds; gifts and other gratuitous transfers from third parties cannot satisfy the minimum. Funds already in Panama may be recognised if the previous international transfer and allocation are evidenced. State-bank deposits are not exempt from the foreign-source requirement. [P35, Articles 2–3, 9 and 11]

19.11 Can a company invest?

Yes, with evidence of beneficial ownership, effective control and allocation of the investment. Article 3 also addresses private foundations and joint holdings. Each principal applicant generally must meet the minimum; a special joint-allocation rule applies to families in the same application. There is no blanket 100% shareholding rule for all routes; Article 8’s specific securities requirements must still be observed.

19.12 Can the application be filed before I enter Panama?

Yes. Article 16 allows filing through a representative with a specific power of attorney before entry. Biometric and foreigners’ registration must be completed before receiving an immigration card.

19.13 Is approval guaranteed within 30 working days?

The law sets maximum periods for individual stages: MICI, 15 working days from admission of the complete file; SNM, 30 working days from formal receipt of the complete file, subject to lawful suspensions. These do not guarantee total duration including preparation and card issuance. [P35, Article 15]

19.14 Which family members may be included?

Assess eligibility individually for spouses, children and parents. Article 17 permits subsequent direct inclusion of children born or adopted later and a spouse married after approval by the principal investor, subject to continuing eligibility, evidence, MICI certification and prescribed payments per dependant. It does not automatically extend status to the family of an adult dependant who later marries.

19.15 Does residence allow me to work?

Residence and work permission are separate. MITRADEL provides category 4B for qualified investors; the activity and professional requirements must be assessed separately.

19.16 Do I automatically become tax resident in Panama?

No. Article 762-N, actual days and connections, and DGI evidence requirements apply independently. Foreign tax liability may also continue.

19.17 Is foreign income always tax-free?

No. Panama applies territorial taxation, but income-source classification under the Fiscal Code and special rules determines the treatment. Blanket assurances are inappropriate.

19.18 Will I automatically become a citizen after five years?

No. Article 14 of Executive Decree 17/2026 provides for a separate application after five consecutive years of residence, with MICI certification and submission through its Investment Directorate. Constitutional and statutory conditions and a separate decision remain necessary; investment does not grant automatic nationality.

19.19 Does Law 493/2025 immediately provide a Panamanian passport?

No. It establishes a basis for a special passport or travel document that does not confer nationality. The six-month statutory implementation period ended in April 2026, but expiry alone does not establish availability. Confirm the implementing rules and operational issuing procedure with the competent authority before relying on this option.

19.20 What if the investment ceases before five years?

Notify changes or cessation within 30 calendar days. MICI grants up to 90 calendar days for a compliant replacement; failure to remedy risks cancellation. Special rules apply to developer-attributable project delay and market fluctuations not attributable to the investor. Article 12 does not provide an automatic additional 90-day force-majeure extension.

19.21 How often must I visit Panama?

Article 31 of Decree Law 3/2008 identifies absence exceeding two years as a cancellation ground unless justified and authorised. The legislation does not prescribe a universal 24-hour visit rule.

19.22 When may I dispose of the investment after five years?

Article 12 requires maintenance for at least five years. Before disposal, verify the start and end dates, annual evidence and outstanding changes. Article 13 concerns the special processing office and document validity; it does not establish a release procedure with 30-day notification and 15-working-day review. This guide therefore does not promise such automatic release.

Primary sources for this section: the sources identified in the relevant chapters. Individual facts may require further analysis.

20 · Legal conclusions

Under Executive Decree 17/2026, Panama’s Golden Visa programme comprises three asset classes and five distinct legal investment structures. It provides direct permanent residence on approval, requires at least five years of investment maintenance, and combines MICI certification with a separate SNM decision. The practical challenge is aligning thresholds, first-sale status, valuation, ownership, beneficial ownership, source of capital, institutional certificates and continuing compliance.

Property thresholds distinguish qualifying first-sale/project property from other property. Qualifying securities require B/.500,000; deposits require B/.500,000 at Banco Nacional de Panamá or Caja de Ahorros, or B/.750,000 at an eligible private bank. Every route requires evidence of source, allocation and maintenance. The decree does not establish a general B/.200,000 minimum per deposit account.

Fischer & Cie.’s approach is to assess eligibility, transitional rules and compliance first, then structure and institutional acceptance, and only then commit capital. Approval does not end the work: annual filing windows, notification and replacement periods, absences, family changes and work requirements need continuing management.

This guide distinguishes legislation, official administrative guidance and practice that has not been conclusively published. It addresses Executive Decree 17/2026, general immigration provisions, banking supervision, Law 493/2025 and document organisation for international applicants, with some examples retained from the German guide. Older programme pages and checklists are not treated as overriding current legislation.

KEY POINT The Golden Visa is an immigration and investment project requiring at least five years of evidence management, with specific filing and response deadlines.

A · Initial application master checklist

B · Evidence maps by investment route

B.1 Registered property

• Purchase / closing agreement, payment receipts and bank transfer trail.

• Current Public Registry certificate: owner, folio, value and encumbrances.

• ANATI certification of property value.

• Threshold and financing: B/.300,000 for a qualifying first sale; otherwise generally B/.500,000. Only the excess may be financed, with traceable financing and the qualifying net minimum maintained.

• For an entity: registry, shareholder, governance and beneficial-ownership records.

• Annual evidence of ownership and maintenance within the 30 calendar days before the immigration resolution anniversary, throughout the five-year period.

B.2 Property — purchase promise / trust

• Notarised purchase promise for qualifying new, previously unoccupied first-sale property of at least B/.300,000.

• Trust agreement with an eligible licensed Panamanian institution.

• Full qualifying deposit and staged disbursement mechanism for obligations under the purchase promise.

• Trustee certification of deposits, disbursements and continued compliance; evidence project status within the statutory annual window.

• Project, title, construction, permit and insolvency due diligence.

• Unwinding and immigration replacement plan.

B.3 Property — direct payment / bank instrument

• Notarised purchase promise and full payment evidence.

• Irrevocable, unconditional first-demand bank instrument in favour of the investor, covering the entire investment paid.

• Keep the instrument effective until construction, separate registration and title registration in the applicant’s name; renew annually and submit to MICI without gaps in coverage.

• Annual evidence within the statutory window; for developer-attributable delay, track 180 working days from the first working day after the contractual deadline, only one replacement purchase promise and the cumulative three-year limit.

• Notify assignment, contractual change or cessation within 30 calendar days; assess the applicable replacement rules before acting.

B.4 Securities

• Securities-house certificate: investor, amount, securities and custodian.

• Certified resolution evidencing a valid SMV licence.

• Evidence of SMV registration or a lawful exemption documented by the custodian.

• Trade and settlement records and foreign transfer trail.

• Annual holdings evidence; for market fluctuations not attributable to the investor, restore the minimum within 90 calendar days after MICI notification. Apply Article 12 to voluntary changes.

B.5 Fixed-term deposit

• Certified deposit instrument and original bank confirmation: holder, amount, term, foreign source and absence of encumbrances. B/.500,000 at Banco Nacional de Panamá or Caja de Ahorros; B/.750,000 at an eligible private bank. Confirm the account structure and available evidence beforehand.

• Bank certificate confirming existence, holder, amount, term, absence of encumbrances and foreign source of capital. The two state banks have no exemption from the foreign-source requirement.

• Verify institution and threshold: Banco Nacional de Panamá / Caja de Ahorros, or a private general-licence bank.

• SWIFT / transfer records and KYC dossier.

• Annual evidence within the statutory window; manage maturity or bank changes under the applicable notification and replacement rules.

C · Property due diligence before residence due diligence

Table C1 · Minimum review

D · Banking and KYC dossier

• Passport, address, tax identification numbers and tax residences.

• Professional / business profile; company registry records and organisation chart.

• Asset statement and documented wealth creation.

• Source of the specific investment amount, with at least twelve months of supporting context if requested.

• Tax returns, financial statements, purchase/sale agreements or inheritance records, as applicable.

• Sanctions, politically exposed person and adverse-media declarations, with explanations of potential matches.

• Transfer plan: originating bank, intermediary bank, destination institution, currency and payment reference.

• Have the proposed immigration bank certificate wording accepted before transferring funds.

E · Project plan and critical path

Table E1 · Illustrative preparation schedule

F · Budget worksheet

Table F1 · Budget without double counting

G · Case-specific checks before committing capital

QUALITY STATUS Executive Decree 17/2026 changes key thresholds, deadlines and replacement rules. The following issues concern checklists, forms and institutional implementation that must be confirmed in writing before a specific filing or irreversible transaction.

1. Check that MICI and SNM checklists and forms expressly reflect Executive Decree 17/2026; do not rely on an older programme page where it conflicts with the decree.

2. Document admission of the complete file, the start of MICI’s 15-working-day period and any deficiency process through official acknowledgements.

3. Confirm document validity by issuing country and current SNM filing requirements.

4. Check that the bank instrument is irrevocable, unconditional and payable on first demand under Decree 17/2026; do not adopt a 2025 SBP model without review.

5. Document the annual evidence form, submission channel, responsible authority and receipt; file within the 30 calendar days before the immigration resolution anniversary.

6. Build separate procedures for Article 8 market fluctuations and Article 12 investment changes. Article 8 restoration runs for 90 calendar days after MICI notification, not from the date of the price fall. Review maturity and security replacements before execution.

7. Do not present refundability or processing of the repatriation deposit as settled until the applicable official procedure is confirmed.

8. Reconcile dependant eligibility, particularly adult children and parents, with current filing requirements.

9. Add current private fees and representative third-party quotations to the individual budget.

10. Check website links before publication and record legal-update monitoring.

H · Source register

H.1 Legislation and procedural sources

H.2 Authorities, registers, statistics and professional credentials

Unless a later check is expressly stated, access dates above are inherited from the German source guide and are identified as such. The English adaptation includes the 27 October 2026 check of Executive Decree 17/2026. This is not a fresh certification of every linked administrative page. Original Spanish legislation and official publications take precedence over summaries; confirm operational requirements at filing.

I · Spanish–English glossary

J · Pre-filing checks: 30, 10 and 1 day before submission

Table J1 · Final quality review

K · Primary-source and proposition matrix

Table K1 · Key propositions and sources

This matrix identifies the main propositions carrying heightened advisory or marketing risk; it does not individually substantiate every explanatory sentence. Reopen the current complete legislation before advising on a particular case.

L · Practical questions requiring written confirmation

Table L1 · Checks before committing capital

DECISION RULE A blog, sales brochure or oral statement cannot resolve these checkpoints. Obtain current official documentation, written confirmation from the authority or institution, or a case-specific legal memorandum identifying its basis.

FISCHER & CIE. · LEGAL INSIGHT FROM PANAMA