More than a simple regulatory update, adopting Form 930 V3 offers an opportunity to observe how Panama's transfer pricing regime has evolved. This annual report has guided taxpayers subject to this obligation for more than ten years.

Since the introduction of transfer pricing rules through Law 33 of 2010, followed by the first Transfer Pricing Report in 2012, Executive Decree 390 of 2016, and subsequent versions of Form 930, Panama's regime has gradually evolved. It now aligns closely with international trends in transparency, economic analysis, and tax risk management.

Resolution No. 201-4247 introduces an updated form and new information fields that strengthen reporting requirements. Articles 762-A to 762-L of the Tax Code and Executive Decree No. 390 of 2016 provide the legal framework.

From identifying transactions to understanding business models

We can read the history of Form 930 as a timeline of the regime's maturity. In the early years, the challenge lay in identifying related-party transactions. Later, the focus shifted to organising and digitising information. Today, the goal is to connect data, allowing us to understand the economic reality behind transactions in greater depth.

The information already existed: Now it's structured

Version 3 doesn't represent a radical change to Panama's transfer pricing rules. Many of the questions appearing on the form today have existed for years in transfer pricing studies, functional analyses (FAR), financial segmentations, and working papers.

The novelty is that this information is no longer scattered; it's now structured within the report. It's vital to remember that Form 930 doesn't replace the obligation to have a Transfer Pricing Study.

Annex 1128V0: From the margin to the origin of the margin

One of the most significant changes is the Financial Information Annex (1128V0). This annex lets you report income statement and balance sheet information for the analysed party.

Traditionally, the form mainly showed the results of the economic analysis. Now, it looks closer at the elements that explain how you reach that result:

• It no longer looks solely at the margin.
• It displays part of its composition.
• It brings the report closer to the economic logic behind comparability analyses.

This helps you better understand the factors driving the profitability of the analysed party. In other words, the form is starting to adopt the language we traditionally find in transfer pricing studies.

Annex 1129V0: When related-party status is no longer a footnote

Perhaps one of the most relevant aspects is the related-party information requested in Annex 1129V0. Historically, many discussions in Panama have started even before the economic analysis, beginning with the determination of the relationship itself.

The grounds for related-party status cover direct and indirect relationships. This annex can help build a more complete map of:

• corporate groups,
• their corporate structures, and
• their value chains.

Annex 1130V0: Assets return to the centre of the conversation

The addition of specific information on fixed assets is particularly interesting from a FAR analysis perspective. For years, functions and risks have captured most of the technical attention, while assets have received more descriptive treatment.

However, assets relate directly to:

• value generation,
• capital intensity,
• comparability adjustments, and
• the explanation of reported financial results.

It's particularly interesting that this increased visibility of assets appears in a version of the form that also requests more detailed information on economic analyses and adjustments. From a transfer pricing perspective, you can't easily analyse these elements in isolation, as assets often influence aspects like capital intensity, productive capacity, and specific comparability adjustments.

A comprehensive reading of Form 930 Version 3

When analysed together, the three new annexes seem to follow a common logic: connecting elements that were previously distributed across studies, supporting documentation, and subsequent audit requests. The form is beginning to align more closely with the economic and functional analysis language that characterises transfer pricing studies.

Sources for consultation

• Resolution No. 201-4247 of 16 June 2026.
• Form 930 Version 3: Transfer Pricing Report.
• Instructions for Form 930 Version 3 published by the DGI.
• Articles 762-A to 762-L of the Tax Code.
• Executive Decree No. 390 of 24 October 2016.