
After the changes Spain made in 2025, Panama's Pensionado is the more straightforward retirement route for most people weighing the two. It asks for a pension of $1,000 a month granted for life, it gives permanent residence outright rather than a permit you renew, and it runs on a single decree article, article 200 of Decreto Ejecutivo 320 de 2008, while Spain replaced two major instruments. Panama also taxes on a territorial basis, so a pension paid from the United States, Canada or the United Kingdom sits outside the Panamanian net.
Spain is still the better answer for some people, and this page says where. But the property route closed on 3 April 2025, and the tax regime commonly attached to it was never available to a retiree in the first place.
Key Takeaways
- Spain's golden visa was repealed by the twenty-first final provision of Ley Orgánica 1/2025, effective 3 April 2025. Permits issued before that date stay valid for their term and renew under the old rules, under two transitional provisions written into Ley 14/2013 (BOE-A-2025-76, checked August 2026).
- The impatriate regime of article 93 LIRPF, the one everyone calls the Beckham Law, requires that your move to Spain be caused by an employment contract, becoming a company director, or an entrepreneurial or highly-qualified activity. A retiree living on pension income satisfies none of these. Someone already inside the regime who then retires is excluded from it (Agencia Tributaria, checked August 2026).
- Panama's Pensionado visa requires a pension of $1,000 a month granted for life, paid by a foreign government, an international organisation or a private company, under article 200 of Decreto Ejecutivo 320 de 2008. It grants indefinite permanent residence (Gaceta Oficial 26104, checked August 2026).
- Spain's non-lucrative residence is the realistic route for a retiree. It prohibits all work and professional activity, its financial threshold is set as a multiple of the IPREM index rather than a fixed figure, and it makes you a Spanish tax resident on worldwide income.
- Panama is not on Spain's list of non-cooperative jurisdictions, current through the June 2026 amendment, and a Spain–Panama double taxation treaty is in force. Panamanian assets do not attract the penalty treatment Spain applies to listed territories (Agencia Tributaria, Anexo IV, checked August 2026).
The two systems, stated plainly
| Panama | Spain | |
|---|---|---|
| Realistic retiree route | Pensionado, $1,000/month lifetime pension | Non-lucrative residence, threshold set as a multiple of IPREM |
| Legal basis | Decreto Ejecutivo 320 de 2008, art. 200 | Real Decreto 1155/2024, in force 20 May 2025 |
| Work permitted | No | No |
| Residence granted | Permanent, indefinite | Temporary, renewable, permanent after five years |
| Property route to residency | Separate investor categories exist, at their own thresholds | Repealed 3 April 2025 |
| Basis of taxation | Territorial: foreign-source income outside scope | Worldwide income once tax resident |
| Wealth tax | None | Yes, with state and regional variation |
| Currency | US dollar, balboa pegged 1:1 | Euro |
Two rows carry most of the decision. The residence row is the reason Panama is simpler to plan around: the Pensionado is granted as permanent and indefinite, where Spain's non-lucrative permit is temporary and renewed until you reach five years. The tax row is a difference of kind rather than degree, and it is worth unpacking properly.
What Panama's Pensionado actually asks for
Article 200 sets one income test and one durability test, and the second is the one people miss. The pension must be at least B/.1,000 a month and it must be vitalicia, granted for life. It may be paid by a foreign government, an international organisation, or a private company, so an occupational pension is not shut out. What does not qualify is a drawdown pot you control, because that is not a pension granted for life however large the balance.
Two provisions worth knowing. If you already own Panamanian property in your own name worth more than B/.100,000, the threshold falls to B/.750. And spouses may combine two pensions to reach the B/.1,000. Where the pension comes from a private company, article 201 adds an evidence step: a letter from a foreign pension-administration, trust, mutual-fund, insurance or banking company certifying that funds exist to guarantee the lifetime pension, proof that the granting company exists and is current, and a payment receipt or bank statement.
How the tax question actually works
Panama taxes territorially. Income that arises outside Panama sits outside the Panamanian net, which is why a foreign pension is normally not a Panamanian tax event at all. Spain taxes its residents on worldwide income, so the same pension is inside the Spanish net from the day you become tax resident, and Spain also levies a wealth tax that varies by autonomous community.
That does not automatically make Spain the more expensive choice. Once you are inside Spain's net, the actual bill runs through the double taxation treaty between Spain and the country paying your pension, and through your own citizenship's rules. US citizens are taxed by the United States on worldwide income wherever they live, and neither country's system changes that.
What the structure tells you is where the complexity sits. In Panama, most retirees are dealing with one country's rules for their pension income. In Spain, they are dealing with two sets of rules and a treaty between them. The specific number for your position, which income streams, which treaty, which community, needs a cross-border adviser who has seen your documents. Bring them this page's structure and they can get to your figure quickly.
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The Beckham Law is not a retirement plan
This assumption turns up in a lot of published tax comparisons, and it is worth taking apart before you rely on one.
The regime in article 93 LIRPF lets certain people who move to Spain be taxed broadly as non-residents for the year of the move plus the following five, at 24% on employment income up to €600,000 and 47% above that. It is genuinely attractive, and it is conditioned on why you moved.
The Agencia Tributaria sets out three qualifying causes: an employment contract, including remote work under the international telework arrangements; acquiring the status of company director; or carrying out an entrepreneurial activity or a highly-qualified professional activity serving emerging companies. Every one of them is economically active.
A retiree on Spain's non-lucrative visa cannot satisfy any of them, and the reason is structural rather than procedural. The non-lucrative visa exists precisely to authorise residence without labour or professional activity. The visa forbids the exact thing the tax regime requires. You cannot hold both.
The point is sharper still for anyone who plans to move for work and then retire in place. Where retirement ends the employment relationship that justified the displacement, it ends the basis for the regime, and the taxpayer drops out of it. The 24% rate does not follow you into retirement.
Warning. If a comparison shows someone entering Spain on a non-lucrative visa and then registering for the Beckham Law, the scenario underneath it cannot happen: those two are mutually exclusive by design. Treat the rest of that page's arithmetic with the same care.
What changed in Spain in 2025
Two reforms landed within months of each other, and guides written before them describe a country that no longer exists.
The first is the golden visa repeal. It was not a standalone immigration bill. The provision was attached to a judicial-efficiency law, which is part of why it caught people out. It took effect three months after publication in the BOE, and the transitional provisions are narrow: they protect investors who had already filed before 3 April 2025, and they preserve existing permits for the term already granted.
The second is Real Decreto 1155/2024, which replaced the 2011 immigration regulation entirely and came into force on 20 May 2025. Non-lucrative residence survives it. If you are reading a guide that cites Real Decreto 557/2011 for Spanish residence procedure, it is citing a repealed regulation.
Neither of these is a Panamanian change. Panama's Pensionado still runs on article 200 of a 2008 decree, and that continuity is part of the case for it, with one honest caveat: Panama has revised other residency categories by executive decree before, and stability in one category is not a guarantee across all of them.
What the repeal did and did not change about buying property
Foreigners can still buy property in Spain. The repeal removed a residence permit, not a purchase right. What it removed is the link between the two.
That changes how you sequence a move. Under the old regime, a purchase could be the thing that produced residence, so buying first was rational. It no longer is. If your route is now the non-lucrative visa, that route is satisfied by demonstrating income and means, and a Spanish property does nothing to advance it while adding a wealth-tax-relevant asset and local property tax before you know whether you want to stay.
Panama's position is different, and worth stating precisely rather than in round numbers. Property-linked residency in Panama runs through categories that are entirely separate from the Pensionado, principally Friendly Nations by real-estate investment and the Qualified Investor route, and they carry different thresholds from each other. Comparison pages routinely collapse them into one figure, which is how a buyer plans around a number that belongs to the other route. Our Panama residency guide sets out which is which, and confirm the current figure with an immigration attorney before you build a plan on it, because these are the provisions Panama has amended most often.
Renting first is the conservative move in both countries. A purchase made before you have lived through a rainy season in Panama, or a Castilian winter, is a purchase made on incomplete information. Our best places to retire in Panama guide covers where to rent while you decide.
Which country fits you
- You want the simplest path to permanent residence: Panama. A $1,000 lifetime pension, one decree article, and permanent status from the start.
- You want your pension taxed by as few systems as possible: Panama, on the territorial basis above. Confirm your own citizenship's rules with an adviser.
- You want to budget without an exchange rate: Panama uses the US dollar, with the balboa pegged 1:1.
- Family in Europe is the deciding factor: Spain, and the non-lucrative visa is a well-worn route. Go in expecting ordinary Spanish residency taxation on worldwide income, and price that properly.
- You have never spent an extended stretch in the tropics: try Panama before committing to it. The heat and humidity here are constant rather than seasonal, and it is the thing arrivals most often underestimate. The highland towns around Boquete are the usual answer, and they are a genuinely different climate from Panama City, so rent in both before you choose.
- You need a plan that survives a rule change: build it on income and means rather than on one specific current provision. Both countries have amended their investor categories; neither has touched the income-based retiree route.
Whichever row is yours, the sequence is the same: rent through a full year, get your tax position modelled before you move rather than after, and use a lawyer in-country to file.
Your next step
Most people arrive at this comparison with the visa question already half-answered and the practical one wide open: which town, what it costs, and what you can actually rent there in the month you plan to land. That part is a shorter conversation than the legal reading suggests. Tell us your pension, your timeline, and what a good week looks like for you, and we will come back with a shortlist of Panamanian towns and real properties that fit. The form below is all it takes, and asking costs nothing.
Frequently asked questions
Can I still get Spanish residency by buying property?
No. The residence visa for investors was repealed by the twenty-first final provision of Ley Orgánica 1/2025, with effect from 3 April 2025. You can still buy property in Spain as a foreigner. It no longer produces a residence permit. Permits granted before that date remain valid for the term they were issued for, and renewals are handled under the rules in force when the original authorisation was granted.
Can a retiree use Spain's Beckham Law to avoid tax on a foreign pension?
No. The regime in article 93 LIRPF requires that the move to Spain be caused by an employment contract, by becoming a company director, or by an entrepreneurial or highly-qualified activity. A retiree meets none of those. It is also incompatible with the non-lucrative visa, which authorises residence specifically on condition that you do not work. If someone already in the regime retires and that ends the employment relationship which justified their move, the basis for the regime ends with it.
What income does Panama's Pensionado visa actually require?
A pension of $1,000 a month granted for life, under article 200 of Decreto Ejecutivo 320 de 2008. It may be paid by a foreign government, an international organisation or a private company, so an occupational pension qualifies; what does not is a drawdown pot you control, because that is not granted for life. The threshold falls to $750 if you already own Panamanian property in your own name worth more than $100,000, and spouses may combine two pensions to reach the $1,000. Figures above these circulate widely online and do not match the decree. The visa grants permanent, indefinite residence rather than a permit needing renewal.
Does Spain treat Panama as a tax haven?
Not currently. Panama does not appear on the Agencia Tributaria's published list of non-cooperative jurisdictions, and it is still absent following the June 2026 amendment to that list. A Spain–Panama double taxation treaty is in force. Panama did appear on a much older Spanish list, which is why outdated sources sometimes still describe it as one, but the current position is what governs your treatment. Confirm the list as at your own filing date, since it is amended periodically.
Which country taxes my pension?
It depends on where you are tax resident and on the treaty between your pension's source country and your country of residence, so there is no single answer. The structural difference is that Panama taxes on a territorial basis, meaning income arising outside Panama falls outside its scope, while Spain taxes its residents on worldwide income. If you are a US citizen, the United States taxes you on worldwide income regardless of where you live, and neither country's system changes that. Get this modelled by a cross-border adviser before you move, not after.
Should I buy property before or after moving?
After, in both countries, unless you have a specific reason not to. The old argument for buying first in Spain was that the purchase produced residency, and that link no longer exists. In Panama the Pensionado does not require property at all, though owning more than $100,000 of it does lower the pension threshold to $750. Renting through a full year lets you test the climate and the neighbourhood before committing capital that is slow and expensive to withdraw.
Is Spain's non-lucrative visa a realistic route for a retiree?
Yes, and it is the main one now that the investor route is closed. It authorises residence without any work or professional activity, and requires you to demonstrate sufficient means, set as a multiple of Spain's IPREM index rather than as a fixed figure, so the amount moves when IPREM does. Confirm the current multiple and the additional amount per family member with the consulate handling your application, since these are the numbers most often quoted out of date.
Sources
- BOE — Ley Orgánica 1/2025, disposición final vigesimoprimera (golden visa repeal) — checked 2026-08-04
- BOE — Ley 14/2013, arts. 63–67 and transitional provisions — checked 2026-08-04
- Agencia Tributaria — Régimen especial de impatriados, art. 93 LIRPF — checked 2026-08-04
- Agencia Tributaria — Anexo IV, jurisdicciones no cooperativas — checked 2026-08-04
- BOE — Real Decreto 1155/2024, Reglamento de Extranjería — checked 2026-08-04
- Gaceta Oficial 26104 — Decreto Ejecutivo 320 de 8 de agosto de 2008, arts. 200–201: pensión vitalicia no inferior a B/.1,000 de gobierno extranjero, organismo internacional o empresa privada; parágrafo B/.750 con propiedad superior a B/.100,000 — checked 2026-08-21
- Servicio Nacional de Migración — Requisitos para Jubilado Pensionado (PRP-JP) — checked 2026-08-21
Do you need help relocating to Panama?
If you're weighing up the move, a licensed broker who lives here can tell you what the areas are really like to live in, and what your money does in each of them.
Email or phone, whichever you’d rather. We pass your details to one licensed broker and no one else, and there’s no newsletter.
Know your budget and timeline already? Send those instead and get a shortlist →


