The Paraguayan tax authority (SET) issued General Resolution No. 134/2023, with rules for submitting transfer pricing studies and documents that clarify transactions with foreign entities.
In Paraguay, when a company engages in transactions with a foreign entity in a low or zero tax jurisdiction, free trade zone, or with a maquiladora, the tax authority assumes this entity is related. To prove that the entity is a third party, the taxpayer will need to submit certain documentation, as set forth in Article 12 of General Resolution No. 115/2022, in addition to the transfer pricing study.
Taxpayers with a fiscal year end (FYE) of either 12/31/2022, 04/30/2023, or 06/30/2023, must submit the transfer pricing study through the SET’s Intake Desk in digital format, in an external storage medium (CD, DVD or USB flash drive), with the content established in articles 3° and 7° of General Resolution No. 115/2022.
The evidentiary documents that disprove the presumptive link with foreign entities, corresponding to the operations carried out in fiscal years 2022 and 2023 by taxpayers with FYE on 12/31/2022, 04/30/2023, or 06/30/2023, must be submitted to the SET’s Intake Desk in portable document format (.PDF extension), within the terms set forth in Article 12 of General Resolution No. 115/2022.
You can access the full text of the regulation here.
For additional information and support for your company’s compliance with these deadlines, please contact BaseFirma’s partner in Argentina, Melisa Gómez, melisa.gomez@basefirma.com