A person connected with Panama who owns assets in other countries may need more than one document, but should not create isolated documents. Planning starts with a map of assets, ownership, family and jurisdictions. Panama’s Private International Law Code contains rules on succession, will formalities and the location of assets; every connected country may add its own tax, succession and registration rules.
The rule that requires an asset-by-asset review
Law 61 of 2015 governs succession in Articles 51–60. Among other rules, Article 52 provides that succession is governed by the law of the place where assets are located. Article 53 addresses will form by reference to the law of the place of execution, while Article 60 also connects assets with the law of their location.
It is therefore unsafe to assume a Panama will resolves every foreign account, property, company or other asset by itself. It is equally unsafe to assume it cannot. Identify the asset, its ownership form and the jurisdiction that must recognize or implement the plan.
The minimum cross-border planning map
- People Nationality, residence, domicile, marital status, children, dependants and beneficiaries.
- Assets Real estate, accounts, investments, companies, insurance, digital assets and relevant personal property.
- Ownership Individual, joint, corporate, fiduciary or foundation ownership.
- Documents Current wills, powers, marital agreements, beneficiary designations and company records.
- Jurisdictions Where each asset sits, where key people live and where proceedings may occur.
- Tax and reporting Analysis required from a qualified tax professional in each country.
- Incapacity Who can act and what document will be recognized if the person cannot decide.
- Implementation Who holds originals, coordinates advisers and keeps the map current.
What Panama’s Judicial Branch has explained
In a public educational article on wills, Panama’s Judicial Branch explained that when property exists abroad, a declaration of heirs obtained in Panama may be taken to the other country to begin succession proceedings there. It is an important practical distinction: a Panama step may form part of the solution without replacing the foreign procedure.
A real international case: Kubicka, C-218/16
Location and form matter
Panama’s rules require attention to where each asset is located and how each disposition was formalized. The design should anticipate which authority must recognize and implement the document.
Classification can affect cross-border recognition
Kubicka concerned a testamentary disposition of German real estate in a succession governed by Polish law. The Court held that the EU Succession Regulation prevented refusal to recognize the effect of the legacy merely because the property state did not know that form of legacy. This is not Panama law; it demonstrates how succession law, registration and cross-border recognition can interact.
“One will for everything” and “one will per country” are not universal rules. Either route can create conflict unless revocation, scope, form, tax, title and executor coordination are reviewed together.
Recommended sequence
Audit assets, family, documents and jurisdictions first. Then identify what can be handled from Panama and what requires foreign counsel, a notary, fiduciary or tax adviser. Coordinate text, execution, custody and periodic review last. International and high-value matters are application-first and privately quoted; third-party fees remain separate unless expressly agreed.
Verifiable sources
- National Assembly: Law 61 of 2015, Private International Law Code.
- Panama Judicial Branch: public guidance on wills and foreign assets.
- Court of Justice of the European Union: Kubicka, C-218/16, non-Panama comparative case.
General information reviewed 25 July 2026. It is not legal, tax, fiduciary or financial advice. The case discussed is a public international decision, not a result obtained for Carolina Solís clients. Strategy depends on the facts, assets, documents and jurisdictions involved.