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October 29, 2021

Paraguayan Government modifies transfer pricing provisions related to the exportation of certain commodities

Taxpayers must register their purchase-sale agreements concluded before 1 November 2021 for exports made after 1 July 2021 by 31 December 2021.

On 14 October 2021, the Paraguayan Government issued Decree No. 6105/21, which modifies certain provisions of the transfer pricing regime applicable to the exportation of certain agricultural products.


On 30 December 2020, the Paraguayan Government published Decree No. 4644/20, which regulates, among other things, the application of the transfer pricing method based on international quotations for the exportation of soybeans and their by-products, rice, corn and wheat. The transfer pricing rules for the exportation of these goods went into effect 1 July 2021.

Decree No. 4644/20 also requires taxpayers to register the purchase-sale written agreements related to these transactions on a web registry, which the Paraguayan tax authority will create.

Decree No. 6105/21

Decree No. 6105/21 modifies Decree No. 4644/20 by establishing that the Paraguayan tax authority will enable the purchase-sale written agreement registry on 1 November 2021.

Additionally, Decree No. 6105/021 requires taxpayers to register their purchase-sale written agreements concluded before 1 November 2021 that are related to exports made after 1 July 2021 by 31 December 2021.


For additional information with respect to this Alert, please contact the following:

Ernst & Young Paraguay - Auditores y Asesores de Negocios, Asunción

 Ernst & Young LLP (United States), Latin American Business Center, New York

Ernst & Young Abogados, Latin America Business Center, Madrid

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific


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