Panama published Resolution No. 201-0717 of 26 January 2023 in Official Gazette No. 29712 on 31 January 2023, which regulates the phases for banks and other financial institutions to comply with the requirements to issue invoices using authorized fiscal equipment or through the e-invoicing system, Sistema de Facturación Electrónica de Panamá (SFEP), as per Law No. 256 of 26 November 2021. As previously reported, Executive Decree No. 3 of 20 January 2023 revised the e-invoicing implementation deadlines for certain taxpayers, including a three-phase approach starting 30 April 2023, 30 June 2023, and 31 August 2023 for operations and services carried out by banks and other financial institutions. Resolution No. 201-0717 specifies the e-invoicing implementation deadlines for bank and financial institutions as follows:

• Phase 1: 30 April 2023 for commissions and surcharges and various services, including online banking, mobile banking, security boxes, check certification, local and international transfers, bank guarantees, and others;
• Phase 2: 30 June 2023 for interest generated by the services provided, such as interest earned on personal loans, auto loans, commercial loans, lines of credit, interim financing, etc.; and
• Phase 3: 31 August 2023 for financial services provided by banks and other financial institutions such as investment banking, exchange houses (currency exchange), fund managers, insurers and reinsurers, factoring, trustees, financial leasing, credit cards, ATMs, and others.

In addition to regulating the three-phase approach, Resolution No. 201-0717 also provides an exemption from e-invoicing for banks with an international license that direct, from an office established in Panama, transactions that are perfected, consummated, or take effect abroad, and carry out other activities that the Superintendency of Banks authorizes. Such banks are exempted as long as they do not generate taxable income within the territory of Panama. Further, Resolution No. 201-0717 provides that banks that have a general license and an international license are subject to the e-invoicing requirements in respect of the operations and financial services provided that are covered under the General License, while those under the international license are exempt.