The enactment of the Tax Procedure Code (CPT) with Law 76 of February 2019 was undoubtedly a fundamental milestone in the history of the Panamanian tax system, since it was a law enacted with the purpose of establishing a general regulation on tax procedure. The purpose is to regulate the legal tax relations between the Treasury and taxpayers, seeking a balance between both parties, as well as greater efficiency on the part of the tax administration.
The CPT has played a fundamental role in the unification of tax procedures -whether in administrative or judicial proceedings- seeking to provide taxpayers and other taxpayers, the tax administration, judges, lawyers and other legal assistants with clear and predictable rules, under the fundamental premise that the tax obligation is a relationship of law and not of power.
These aspects have undergone considerable development in recent years, not only in terms of positive law but also due to the constant evolution of the doctrine. So much so that the entry into force of all the articles of the CPT in the Republic of Panama raises several questions as to its entry into force, the need for modification and its re-engineering.
In recent tax law forums in the country, this has been the subject of debate, and different positions on the need to have a TPC for next year are evident. We consider that the TPC has room for improvement and if a proposal for modification and re-engineering of the TPC were to be made, one of its aims should be to create the basis for an efficient tax system.