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Leaving your home tax residency for Panama: the 18-month plan (2026)

You're thinking of moving to Panama but you're not sure whether you'll really be treated as a non-resident for tax. Here's the US reality (citizenship-based taxation), the UK Statutory Residence Test, the exit tax, foreign-account reporting, and the 18-month timeline to leave cleanly without getting reassessed in 3 years.

Inside Panama2026-05-20✓ field-verified

Tax document and passport on a desk
Tax document and passport on a desk

You can’t just “decide” you’re a non-resident for tax

Your home country sets the criteria for tax residency, and the tax authority applies them unilaterally. Your perception of the situation doesn’t matter — only the facts do. And one country’s rules differ sharply from another’s. Two cases dominate for our readers: the United States (the hard case) and the United Kingdom.

If you’re a US citizen or green-card holder — read this first

The US is one of only two countries that tax on citizenship, not residency. Moving to Panama does not make you a US non-taxpayer. As long as you hold US citizenship or a green card, you file a US return on your worldwide income every year, wherever you live.

What moving abroad does give you:

The only way to truly exit the US tax system is to renounce citizenship (or formally abandon the green card) — which can trigger the §877A exit tax (see below). Be honest with yourself about which path you’re on before you start.

If you’re a UK resident — the Statutory Residence Test

The UK uses the Statutory Residence Test (SRT). It works in three layers:

Layer What it checks
Automatic overseas tests E.g. < 16 days in the UK, or full-time work abroad with limited UK days → automatically non-resident
Automatic UK tests E.g. 183+ days in the UK, or your only home is in the UK → automatically resident
Sufficient ties test Combines UK days with ties (family, accommodation, 90-day, work, country). The more ties, the fewer UK days you’re allowed

Split-year treatment can make part of your departure year non-resident. And beware temporary non-residence: if you return to the UK within roughly 5 years, certain gains and income realized while away can be taxed on return.


No tax treaty with Panama

Many expats expect a bilateral treaty to resolve “dual residence” in their favor. There is no comprehensive income-tax treaty between Panama and the US (only a TIEA for information exchange), nor a full one with the UK.

Consequences:


The 18-month timeline to leave cleanly

The big mistake most people make: believing they become a “non-resident” the day they board the plane. That’s false. A change of tax residency is a process that spans at least 18 months.

Period Key steps
M-18 to M-12 Firm decision. Net-worth review. Exit-tax assessment. Global tax plan.
M-12 to M-9 Engage a cross-border tax adviser if net worth > USD 500k. Start the Panama visa.
M-6 to M-3 Sell or let your home property. Wind down home-country tax-advantaged accounts. Choose insurance.
M-3 to M-1 Panama housing found. Panama accounts started. Cease/transition home-country work.
M0 (departure) Flight to Panama. Notify the tax authority (US: keep filing as expat; UK: file form P85).
M+1 to M+3 Settle in Panama. Bank account. Cédula. Contador engaged.
M+10 to M+12 DGI Panama tax-residency certificate. First post-departure home filing.
M+13 to M+18 Non-resident status recognized (UK) / clean expat filing position (US).

⚠️ The fatal rushed-departure mistake: you trigger an exit tax you could have planned around, you forget to report a foreign account → heavy penalties, your final home-country assessment lands on you, and you end up with murky health cover for 3-6 months. Count on 18 months minimum.


The exit tax

US — IRC §877A (only if you renounce)

The US exit tax applies only when you expatriate (renounce citizenship or give up a long-held green card) and you’re a “covered expatriate” — meaning you hit any of:

A covered expatriate is taxed as if they sold all worldwide assets at fair market value the day before expatriation (a mark-to-market tax), above an exclusion amount. If you’re not renouncing, §877A doesn’t apply — but you also haven’t left the US tax system.

UK — no general exit tax, but watch CGT and temporary non-residence

The UK has no broad exit tax on unrealized gains for individuals. But: gains on UK land and property remain taxable, and the temporary non-residence rules can tax gains/income realized abroad if you return within ~5 years. Time disposals of big assets for after you’re clearly non-resident.

💡 If you hold more than ~USD 500k in appreciated assets or a controlling stake in a company, consult a cross-border tax adviser 12-18 months before departure. USD 2,500-5,000 for a full study can save you tens of thousands.


Foreign-account reporting (FBAR / FATCA / CRS)

While you remain a tax-resident (UK) or a US person (US), you must report foreign accounts.

US persons

UK residents

Typical accounts a new Panama expat reports

Account Reported by
Personal Wise USD FBAR / Form 8938 (US); worldwide income (UK while resident)
Personal Wise EUR FBAR (US)
Panama bank (personal) FBAR (US)
SA account (Multibank, if applicable) FBAR + likely Form 5471 (US CFC)
PayPal Business SA FBAR (US)
Binance / Kraken / Coinbase FBAR if custodial (US)

That’s typically 4-6 accounts to report each year while you remain in the home-country net.


Notifying your home-country tax authority

US

You don’t “deregister” — you keep filing a 1040 as a US person abroad. Update your address, claim FEIE/FTC where relevant, attach FBAR/8938. If you renounce later, you file a final return + Form 8854.

UK

  1. On departure: file form P85 (or report leaving via Self Assessment) with your exact departure date and new Panama address.
  2. The following filing season: complete Self Assessment with the residence pages (SA109), claiming split-year treatment if applicable.
  3. Keep evidence of your departure date (flight, Panama lease) — this date is crucial and must be documented.

⚠️ Anticipate a residence enquiry: authorities can open a residence review in the 18-24 months after you leave. Prepare ahead: Panama utility bills, your lease, flights, and the DGI tax-residency certificate. With a clean file, you answer in 30 minutes.


Your home-country accounts: keep, close, transform

Account / product Keep? Recommended action
Main current/checking account Yes (one) Simplify, report on FBAR
Ordinary savings Yes Keep for home-currency savings
Tax-advantaged accounts (US: IRA/401k; UK: ISA) Mixed IRA/401k: keep, no new contributions without earned-income basis. ISA: loses its tax-free status for non-residents — you can keep it but can’t add to it
Brokerage (taxable) Yes, but Many US brokers restrict non-resident accounts — confirm before moving
Pension (US 401k / UK SIPP) Yes Leave invested; mind withholding on withdrawals
Business accounts No Close if the activity is wound down

Note (US): some US brokerages freeze or close accounts once your address is abroad. Sort out a broker that accepts overseas residents before you move.


Health insurance: international vs local

Once out of your home public system, you have no home cover abroad (Medicare doesn’t travel; the NHS is residence-based). 3 options to bridge:

Option Annual premium For whom
International private (Cigna Global, Allianz, GeoBlue, IMG) USD 1,500-5,000 Families, potentially costly care, frequent travelers
Local Panamanian (ASSA, Mapfre Panama) USD 600-1,500 Healthy singles on a tighter budget
Hybrid (local + international top-up) Variable Best coverage-to-cost for many

Timing: buy at least 30 days before departure. Underwriting and policy activation take time.


The first 12 months in Panama — consolidation

Months 1-3 — Administrative setup

Months 3-6 — Economic consolidation

Months 6-12 — Documenting tax residency

The DGI Panama tax-residency certificate is the central document that formalizes you as a Panamanian tax resident in the eyes of your home authority.

⚠️ The step you must not skip: most expats never request a tax-residency certificate from DGI Panama. The consequence: 3-4 years later, the home authority asks them to prove Panamanian tax residency. Without an official certificate = reconstructing proof from scattered documents. Request the certificate within the first 12 months. USD 50 and 8 weeks.


Inside Panama’s Memo #6: Leaving home tax residency for Panama

What you’ve just read is the skeleton. Inside Panama’s Memo #6 details each step with:

PDF + mobile HTML format, 40 pages, updated May 2026.

👉 Buy the memo — $34

Or join the Inside Panama newsletter for our expat-tax updates every week:

📧 Join the newsletter

⚖️ This article is informational and country-general. Tax residency is fact-specific and the rules differ sharply by nationality. Always confirm your position with a cross-border tax adviser qualified in your home country before acting.


Read also


Article published on 20 May 2026 by the founders of Inside Panama, a brand of LAS FUNDADORAS HERMANAS S.A. (RUC 155776412-2-2025).

Questions & answers

What readers ask us

As a US citizen, can I stop paying US tax by moving to Panama?

No. The US taxes its citizens and green-card holders on worldwide income regardless of where they live. Moving to Panama does not end your US filing obligations — only formally renouncing your citizenship (or abandoning the green card) does, and that can trigger the §877A exit tax if you're a "covered expatriate". You can reduce US tax with the Foreign Earned Income Exclusion (Form 2555) and Foreign Tax Credit (Form 1116), but you keep filing.

How does the UK Statutory Residence Test work?

The SRT decides your UK residence by automatic overseas tests, automatic UK tests, and a "sufficient ties" test that combines days in the UK with ties (family, accommodation, work, 90-day, country). Fewer ties = fewer UK days allowed before you're resident. Split-year treatment can apply in your year of departure. Beware temporary non-residence: return within ~5 years and certain gains/income can be clawed back.

How long does a clean exit take?

Count on 18 months to do it properly: 6 months of pre-departure preparation, the year of departure, then 12 months of consolidation with the DGI Panama tax-residency certificate. Rushing it = reassessment risk later.

Is there a tax treaty between Panama and the US or UK?

There is no comprehensive income-tax treaty between Panama and the US (only a TIEA for information exchange) nor a full one with the UK. So there's no automatic tie-breaker to resolve dual residence, and no automatic credit mechanism beyond your home country's unilateral foreign-tax-credit rules.

Do I still have to report my Panama accounts?

US persons: yes — FBAR (FinCEN 114) for foreign accounts over USD 10,000 aggregate, and Form 8938 (FATCA) above higher thresholds, every year you remain a US person. UK residents: report worldwide income while UK-resident; once non-resident, UK reporting narrows but CRS still shares your Panama account data with HMRC.

What health insurance during the transition?

You lose home-country public cover (Medicare doesn't travel; the NHS is residence-based). 3 options: international private insurance (Cigna Global, Allianz, GeoBlue, IMG; ~USD 1,500-5,000/year), local Panamanian insurance (ASSA, Mapfre; ~USD 600-1,500/year), or a hybrid. Buy at least 30 days before departure.