
When will Panama leave the EU tax blacklist? If France is right, in October. In an interview with La Estrella de Panama published on September 17, 2026, French trade minister Nicolas Forissier said a final EU decision on removing Panama should come in early to mid October, and that France would then take Panama off its own national list as well.
The EU Council confirms that the next revision of its list of non-cooperative jurisdictions for tax purposes is scheduled for October 2026. Panama has been on that list, formally known as Annex I and commonly called the blacklist, since February 2020.
Casa Solution has followed this story since the October 2025 review. This is the closest Panama has come to an exit.
What Did Mulino and France Say This Week?
Speaking at the XVIII National Competitiveness Forum on September 16, President Jose Raul Mulino called it unacceptable that a country that has made sacrifices to modernize its regulatory and financial framework remains on discriminatory lists.
Foreign Minister Javier Martinez-Acha said the government is optimistic that it will soon be able to share good news from Brussels.
The stronger signal came from Paris. Forissier told La Estrella that Panama has made an enormous effort to meet transparency standards and that, in France’s view, there is no longer any reason to keep it on the list. France and Spain have both publicly backed Panama’s removal.
Why Is Panama on the EU List in the First Place?
The EU’s official reasoning is short. In its February 17, 2026 conclusions, the Council stated that Panama has a harmful foreign-source income exemption regime and has not resolved the issue. Panama also committed to fixing deficiencies in how it exchanges tax information on request, identified by the OECD Global Forum.
The issue is not Panama’s territorial tax system as such. The EU’s concern is that foreign income could go untaxed everywhere when it flows through Panamanian entities that have no real presence in the country.
What Has Panama Done to Fix It?
| Date | Step |
|---|---|
| February 2026 | EU keeps Panama on the list; Mulino bars EU-based companies from public tenders in response |
| May 28, 2026 | Law 526 on economic substance is enacted |
| September 2, 2026 | Executive Decree 32 regulates the law, within the 90-day deadline |
| September 16-17, 2026 | Mulino and the foreign minister press for exit; France says the decision is expected in October |
| October 2026 | Scheduled EU Council review of the list |
Law 526 applies to Panamanian entities that belong to a multinational group and earn passive foreign income such as dividends, interest, royalties and capital gains. Those that cannot show real substance in Panama, including staff, facilities, strategic decisions and operating costs, will pay a 15% tax on that net income. The rules apply from fiscal year 2027.
We covered the law in detail in Panama Approves Economic Substance Law.
What Actually Changes if Panama Is Removed?
Being on Annex I is not just a label. EU member states agreed in 2019 to apply at least one of four tax defensive measures against listed countries, and the Council says every member state now does.
| Area | While Panama is listed | After removal |
|---|---|---|
| EU tax treatment | Member states may deny deductions for payments to Panama, apply stricter CFC rules, add withholding taxes or limit dividend exemptions | These Panama-specific measures fall away as member states update their rules |
| Tax audits | Reinforced monitoring and higher-risk audits for transactions involving Panama | Panama transactions are treated like those of other cooperative countries |
| France | Panama is on France’s 2026 list of non-cooperative states, which can bring heavier taxes, in some cases up to 75% withholding on certain payments | France says it will follow the EU and remove Panama |
| EU funding | Funds from several EU instruments cannot be channeled through entities in listed countries | That restriction no longer applies to Panama |
| Reputation | Banks, lawyers and compliance teams flag Panama as higher risk | One of the last major international objections disappears |
Exact effects vary by country, because each EU member state chooses which measures to apply and some also keep their own national lists.
What Does Not Change?
Delisting will not change Panama’s territorial tax system for local income, the rules for foreigners owning property, or the residency programs. Law 526 also stays in force regardless of the EU’s decision.
Banks will continue to apply their own due diligence. The difference is that a Panamanian company, foundation or bank account will no longer start every conversation with a red flag attached.
Why It Matters for Real Estate
For European buyers, the list has been a quiet but real deterrent. Holding property through a Panamanian corporation or foundation, receiving rental income, or selling an investment could raise tax questions back home that simply do not arise with other countries.
Removal takes that friction away. It is especially relevant for buyers from France, which has applied some of the toughest national rules, and for European companies weighing Panama as a regional base. More regional offices mean more executive demand in areas like Costa del Este and Punta Pacifica, and more confidence for lifestyle buyers looking at Boquete or the Pacific beaches.
As we noted in our June analysis, the positioning happens before the announcement, not after it.
Is the Exit Guaranteed?
Not yet. Until the EU Council formally adopts its updated list, nothing changes. Panama also committed to requesting an in-depth review of its tax information exchange from the OECD Global Forum before July 17, 2026, a separate track from the substance law that the EU will weigh as well.
Still, the combination of a regulated substance law, public support from France and Spain, and a specific October timeline makes this the strongest position Panama has been in since it was relisted in 2020.
If you are a European buyer or investor considering Panama, Casa Solution can help you evaluate properties and locations while you confirm the right ownership structure with your tax advisor.
Tax regulations and individual circumstances vary by country. This article is intended as general information and should not replace advice from a qualified attorney or tax professional in Panama and in your home country.
Article written: September 18, 2026