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April 12, 2022

Paraguayan Tax Authority publishes requirements for preparing local transfer-pricing technical-study report and eliminates conflict-of-interest provision for auditors

The transfer-pricing technical-study report for tax year 2021 is due 31 October 2022. Taxpayers should prepare now for the filing.

In General Resolution No. 115/22 (issued 07 April 2022), the Paraguayan Tax Authority establishes the requirements for preparing the transfer-pricing (TP) technical-study report (TP report), as well as the due date for submitting the TP report.


Law No. 6380/19 established TP rules as part of a major tax reform in Paraguay. The TP rules entered into force on 1 January 2021, with the first TP report due in 2022, for the tax year ending 31 December 2021. The law, however, did not set out what information had to be included in the TP report or the due date for submitting the report.

General Resolution No. 108/21 established a conflict-of-interest provision under which the same professional may not provide both TP documentation and auditing services for tax purposes to the same taxpayer in the same tax year.

General Resolution No. 115/22

General Resolution No. 115/22 establishes the requirements for preparing, and the due date for filing, the TP report and eliminates the conflict-of-interest provision established by General Resolution No. 108/21.

Taxpayers whose gross income in the tax year under analysis exceeds PYG10 billion (approx. US$1.5 million) must prepare and submit a TP report. Those that do not have gross income exceeding PYG10 billion are not required to submit the report, but the tax authority may require documentation to support the arm’s-length nature of their related-party transactions.

For tax years ending 30 April, 30 June or 31 December 2021, the TP report is due 31 October 2022. For tax years ending 30 April, 30 June or 31 December 2022 onwards, taxpayers must file the TP report with the tax authority in the seventh month after the company’s tax year ends.

General Resolution No. 115/22 entered into force on 8 April 2022 and applies 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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