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January 6, 2022

Paraguayan Tax Authority creates registry of authorized local transfer pricing professionals

Transfer pricing professionals must register with the registry of authorized local transfer pricing professionals to prepare and sign TP Technical Study Reports in Paraguay.

In General Resolution No. 108/21 (issued 30 December 2021), the Paraguayan Government creates a registry of authorized local transfer pricing (TP) professionals, as well as the requirements for registration.


Law No. 6380/19 established TP rules as part of a major tax reform in Paraguay. The rules entered into force on 1 January 2021, with the first TP Technical Study Report due in 2022, for the tax year ending 31 December 2021. According to the provisions of Law No. 6380/19, only local professionals registered with the Paraguayan Tax Authority as TP specialists may prepare and sign TP Technical Study Reports for compliance purposes in Paraguay.

General Resolution 108/21

General Resolution No. 108/21 establishes the documentation and steps required to register with the Tax Authority as a local TP professional authorized to prepare and sign TP Technical Study Reports in Paraguay.

In addition, General Resolution No. 108/21 establishes a conflict-of-interest provision under which the same professional cannot provide both TP documentation and auditing services for tax purposes to the same taxpayer in the same tax year. As such, authorized local TP professionals may not prepare the TP Technical Study report if they are members of a firm that also provides auditing services for tax purposes to the same client, regardless of whether the professionals are part of an independent team.

The registry and conflict of interest provision entered into force on 1 January 2022, and apply to tax year 2021 and onwards.


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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