Paraguay Transfer Pricing

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

The law is Ley N° 6380/2019 "De Modernización y Simplificación del Sistema Tributario Nacional", Libro I, Título I, Capítulo III, "Normas Especiales de Valoración de Operaciones" (arts. 35 to 39), read in the text published by the Biblioteca y Archivo Central del Congreso Nacional (BACN). The regulation is Decreto N° 4644/2020, in force for operations from 1 January 2021 (and from 1 July 2021 for the commodity export rule); its art. 5 (low or nil tax jurisdictions) was replaced by Decreto N° 7402/2022. The technical study is regulated by Resolución General N° 115/2022 of the former Subsecretaría de Estado de Tributación, now the Dirección Nacional de Ingresos Tributarios (DNIT). All were read in the copies the DNIT publishes. The rules apply only to the business income tax (IRE). Amounts are in guaraníes (G). For a calendar-year taxpayer, the 2026 fiscal year ends on 31 December 2026 and its study is due in July 2027.

Who this applies to

• IRE taxpayers with related-party operations (art. 35; Decreto 4644 art. 3): with related parties resident abroad; and with related parties in Paraguay only when, for one of the two parties, the operation is exempt, exonerated or outside the IRE. Domestic operations taxed on both sides are excluded (RG 115/2022 art. 6(g)).
• Presumed related parties (art. 37, penultimate paragraph): operations with residents of low or nil tax countries or jurisdictions, with free-zone users and with maquila companies are presumed to be between related parties, unless the taxpayer proves otherwise with the documents of RG 96/2021 art. 4, communicated through Marangatu (RG 115/2022 art. 12).
• Related parties (art. 37): two or more persons where one participates directly or indirectly in the management, control or capital of the other. Capital: holding directly or indirectly more than 50% of the voting capital (or of an entity whose capital is not in shares). Control or management: the practical ability to influence another's business decisions, shown through appointing managers or directors, dominant contractual or functional influence, or credit rights. "Person" includes individuals, companies, permanent establishments, trusts and similar entities; a permanent establishment is related to its head office and the head office's other establishments.
• Low or nil tax country or jurisdiction (Decreto 4644 art. 5, as replaced by Decreto 7402/2022): one that both taxes the income at an effective or nominal rate below the IRE rate Paraguay would apply to similar operations and has no bilateral or multilateral agreement in force with Paraguay allowing an effective exchange of information.
• Not in scope: individuals paying IRP; IRE taxpayers in SIMPLE or RESIMPLE for the study (RG 115/2022 art. 2), although the arm's length rule in art. 35 still binds IRE taxpayers generally.

Operations left out of the analysis (RG 115/2022 art. 6): forestry and real estate sales taxed on the 30% presumed base (art. 19); international operations on the 30% presumed base (art. 20); cash capital contributions and cash dividends in guaraníes; account reclassifications that do not affect results; operations with the State; domestic related-party operations taxed on both sides. Commodity exports under art. 38(7) are reported separately, not analysed in the study.

When to refer. Refer to a specialist for: preparing the technical study (it must be ratified by a professional on the DNIT register); business restructurings and intangibles valuation; financial transactions beyond the interest rule; mutual agreement procedures under a treaty; disputes. The IRE return, the 30% cap on related-party interest, royalties and technical assistance (art. 15.23) and the non-resident tax (INR) on payments abroad: paraguay-corporate-income-tax.

Rates, bands and thresholds

Item	Rate or amount	Year	Source
Related parties, capital test (art. 37)	More than 50% of voting capital, direct or indirect	2026	https://www.bacn.gov.py/leyes-paraguayas/9332/ley-n-6380-de-modernizacion-y-simplificacion-del-sistema-tributario-nacional
Technical study (ETPT) required (art. 39; Decreto 4644 art. 27)	Prior-year gross income above G 10,000,000,000 with in-scope related-party operations; any size for operations with low or nil tax jurisdictions, free-zone users or maquila companies	2026	same
Tax on a transfer pricing adjustment (Decreto 4644 art. 30; law art. 21)	The adjustment is Paraguayan-source net income taxed at the IRE rate of 10%, paid annually	2026	https://www.dnit.gov.py/documents/20123/199761/Decreto+N%C2%B0+4644-2020.pdf/54a42ca3-8159-d73a-af7f-4a8986e66d31
Range (Decreto 4644 art. 11)	Interquartile range of two or more comparables; outside the range and reducing the IRE base, adjust to the median	2026	same
Goods under the commodity export rule (Decreto 4644 art. 21)	Soya; soya products (oils, meals, pellets, expellers); maize; rice; wheat	2026	same
ETPT filing month, year-end 31 December (RG 115/2022 art. 9)	July of the following year, on the informative-returns calendar day	2026	https://www.dnit.gov.py/documents/20123/209148/RG+115_Por+la+cual+se+reglamenta+el+ETPT+y+otras+disposiciones+sobre+PT_VF.pdf/d1d362e5-9688-3876-4303-3fa62159636d
ETPT filing month, year-end 30 April / 30 June (RG 115/2022 art. 9)	November of the same year / January of the following year	2026	same
Rebutting the presumed relationship, year-end 31 December (RG 115/2022 art. 12)	Communication in March of the following year (30 April year-end: July; 30 June: September)	2026	same
Adding obligation 957-ETPT to the RUC (RG 115/2022 art. 8)	Within 30 working days after the year-end, starting 1 January of that year	2026	same
Fine, late rebuttal documents or late DJI-Num 7 (RG 115/2022 art. 13)	G 900,000	2026	same
Fine, late or inaccurate ETPT, or records not kept (RG 115/2022 art. 13)	The maximum contravención fine set by the Executive at the due date	2026	same
Comparability adjustment for working capital (RG 115/2022 art. 5)	Cash cycle = receivable days plus inventory days less payable days; positive: lending rate; negative: deposit rate	2026	same

The base

The arm's length principle (arts. 35 and 36). In-scope operations must use the prices and terms that independent parties would have agreed in comparable operations under similar conditions. If not, the DNIT sets them. Operations are comparable when no difference significantly affects the price or margin, or reasonable adjustments remove it. Compare the characteristics of the operation (for loans: principal, term, guarantees, solvency and rate; for services: nature and know-how; for goods: physical features, quality and availability; for intangibles: type, duration and protection; for shares: book equity, discounted cash flows or the last quoted price), the functions, assets and risks of each party, contract terms, economic circumstances and business strategies.

The methods (art. 38; Decreto 4644 arts. 6 and 12 to 16):

1. Comparable uncontrolled price (CUP), applied first.
2. Resale price: resale price × (1 less the gross margin over net sales of independent parties).
3. Cost plus: cost × (1 plus the gross margin over cost of sales of independent parties).
4. Profit split: combined operating profit allocated as independent parties would, by assets, costs and expenses.
5. Residual profit split: a routine return by methods 1, 2, 3, 4 or 6, then the residual split by the significant intangibles of each party.
6. Transactional net margin: the operating margin of comparable independent companies, using profit indicators based on assets, sales, costs, expenses or cash flows.

The other methods are used when CUP is not appropriate. The most appropriate method is the one that best fits the facts and gives the most reliable measure, taking account of each method's strengths and weaknesses, the functional analysis, the availability and reliability of data, and the degree of comparability (Decreto 4644 art. 6). The tested party may be the Paraguayan taxpayer or the related party, domestic or foreign (Decreto 4644 art. 7).

The range (art. 38; Decreto 4644 art. 11). With two or more comparables, compute the interquartile range and the median of the prices, amounts or margins. A result inside the range is arm's length. A result outside the range that reduces the IRE base is adjusted to the median.

Intragroup services (Decreto 4644 arts. 17 to 19). A service charge is arm's length if the service was actually provided, it gave or was expected to give the recipient a benefit an independent party would pay for, and the price matches comparable services. It is not arm's length if it was already paid for or duplicates another service, if the withholding due on it was not made, or if it is a shareholder activity: the parent's legal structure (shareholder meetings, share issues, supervisory board), the parent's reporting and consolidation, or raising funds to buy participations that do not benefit the Paraguayan taxpayer. Services to several related parties without specific identification are allocated by reasonable, measurable keys tied to the benefit.

Commodity exports (art. 38(7); Decreto 4644 arts. 21 to 26). For soya, soya products, maize, rice and wheat, the export price for IRE purposes must be at least the price quoted on transparent international or regional markets or exchanges on the date of the "cumplido de embarque" (shipment), or the day before if there was no quote that day. The contract-date quote may be used only if the contract is registered with the DNIT ("Registro de Contratos de Compraventa"), including fixed-price (FLAT) and futures contracts. When the invoice price is below the reference, the IRE base includes the difference. The decree applies it to the taxpayers it covers (Decreto 4644 arts. 3 and 21); whether it also reaches exports to unrelated buyers is not settled by the texts read (see "Not yet confirmed"). These exports are not analysed inside the ETPT, only reported in a separate section with the quantity and amount exported to related parties (RG 115/2022 art. 3); the exports are reported each month on the DJI-Num 7, the month after shipment (RG 86/2021 art. 12 as replaced by RG 115/2022 art. 17).

Effect of an adjustment (Decreto 4644 art. 30). The adjustment is Paraguayan-source net income taxed at the IRE rate, paid annually through the IRE.

Related rules in the IRE base (see paraguay-corporate-income-tax): related-party sales and services are valued at market price (art. 8.4); interest charged on loans the company makes cannot be below the BCP average deposit rate (art. 8.11); interest, royalties and technical assistance paid to partners, head office or related companies are deductible only at market value, with the tax paid, and within 30% of net income (art. 15.23).

Exception table.

Situation	Treatment
Sale to a related company in Paraguay, both IRE-taxed	Out of the ETPT (RG 115/2022 art. 6(g)); market value still required by art. 8.4
Sale to a related cooperative or an exempt entity in Paraguay	In scope (art. 35)
Purchase from an unrelated supplier in a low or nil tax jurisdiction	Presumed related: in scope and in the ETPT at any size, unless the presumption is rebutted by the March communication
Purchase from a free-zone user or maquila company	Presumed related, as above
Group with prior-year gross income of G 9,000,000,000 and foreign related-party services	Arm's length applies; no ETPT filing (threshold not passed), but the DNIT can ask for support (RG 115/2022 art. 11)
Soya export to a related foreign buyer below the shipment-date quote	Commodity rule: IRE on the difference to the quote (or to the registered contract price)
Cash dividend paid in guaraníes to a foreign parent	Excluded from the analysis (RG 115/2022 art. 6(e)); IDU at 15% applies
Management fee for the parent's consolidation and shareholder meetings	Not arm's length (Decreto 4644 art. 18): not deductible

Deadlines and filing

1. Check the threshold each year: gross income of the previous fiscal year above G 10,000,000,000 and in-scope operations, or any operation with a low or nil tax jurisdiction, free-zone user or maquila company.
2. Add obligation 957-ETPT to the RUC within 30 working days after the year-end, starting 1 January of the year to report (RG 115/2022 art. 8). It can be removed after two consecutive years with no in-scope operations, within the same 30-day window. Late RUC updates draw a contravención fine.
3. Rebut a presumed relationship, if possible: Marangatu "Comunicación de desvirtuación de la vinculación presuntiva", with the RG 96/2021 art. 4 documents in PDF, in March after a 31 December year-end (RG 115/2022 art. 12).
4. Prepare the ETPT with the content of RG 115/2022 art. 3: group and local entity background, organisation and shareholding charts, business lines, functions, risks and assets, contracts (date, parties, tax ID and residence, object, amount, currency, payment, term), the method and why others were rejected, profit indicator, comparables with sources and rejections, adjustments with formulas, the median and interquartile range, financial data, conclusions and any adjustment; and the related-party operation types from its Anexo.
5. File it through Marangatu in July after a 31 December year-end (July 2027 for 2026), on the informative-returns calendar day by the last RUC digit (0 = 8th, 1 = 10th, 2 = 12th, 3 = 14th, 4 = 16th, 5 = 18th, 6 = 20th, 7 = 22nd, 8 = 24th, 9 = 26th; DNIT deadlines page). Attach the study in PDF and the working papers as spreadsheets (.xls, .xlsx or .ods) with live formulas, and enter the qualitative and quantitative summary of related-party operations (RG 115/2022 arts. 7 and 9).
6. Ratification: the authorised transfer pricing professional on the DNIT register (Registro PAPT) ratifies the study in Marangatu with their own key; the filing counts as made on the taxpayer's filing date once ratified. A year with no in-scope operations still needs an ETPT "Sin Movimiento", without ratification.
7. Pay IRE on any adjustment in the annual IRE return (Form 500, due in April 2027 for 2026), before the study is due.
8. Keep the supporting documents for the limitation period (RG 115/2022 art. 10; law art. 39). The external tax auditor's report states only whether the taxpayer must file the ETPT (RG 115/2022 art. 16).
9. Commodity exporters in scope file the DJI-Num 7 each month after shipment and register forward or fixed-price contracts before relying on the contract-date quote.

Penalties and interest

• Fixed fines (RG 115/2022 art. 13, under Ley 125/1991 art. 176): G 900,000 for late rebuttal documents and for a late DJI-Num 7; the maximum contravención fine set by the Executive, in force at the due date, for a late ETPT, an ETPT with inaccurate data, and failure to keep the supporting documents for the limitation period.
• On the tax: an adjustment the DNIT makes raises the IRE, with mora (4% to 14% plus the surcharge rate fixed by the Executive), omisión de pago (up to 50% of the tax) or defraudación (one to three times) under Ley 125/1991 arts. 171, 175 and 177 (DNIT copy of Ley 125/1991). Decreto 4644 art. 29 sends all sanctions to Libro V of Ley 125/1991.

Cross-border points

• Withholding on related-party payments abroad. Interest, royalties and service fees paid to a foreign related party bear INR at 15% on 100% of the amount (Ley 6380 art. 75(6)), and IVA withholding of 100% where the service is used in Paraguay (see paraguay-iva). A service fee on which the withholding was not made is not arm's length (Decreto 4644 art. 18(b)).
• Treaties. A double tax convention can give a corresponding adjustment or a mutual agreement procedure; Ley N° 7271/2024 approved the convention with Spain. Check whether a convention is in force before relying on it.
• Country-by-country reporting and a master-file / local-file split are not in the texts read; the ETPT's group sections cover similar ground.

Worked examples

Example 1: service company paid on cost plus, outside the range

Servicios Andinos S.A. provides back-office services to its Brazilian parent for its costs plus 2%. Its 2025 gross income was G 12,000,000,000, above G 10,000,000,000, so it must file an ETPT for 2026. In 2026 its costs for these services are G 1,000,000,000. The study tests Servicios Andinos with the net cost plus margin (transactional net margin method) and finds comparables with an interquartile range of 3.5% to 7.0% and a median of 5.0%.

• 2% is below the range and reduces the IRE base, so the margin is adjusted to the median: 5.0% less 2.0% = 3.0 points.
• Adjustment: 3.0% of G 1,000,000,000 = G 30,000,000 of Paraguayan-source net income.
• IRE: 10% = G 3,000,000, in the 2026 IRE return (April 2027). The study itself is filed in July 2027.
• Had the margin been 4%, inside the range, there would be no adjustment.

name: Cost-plus services below the interquartile range, adjusted to the median, 2026
inputs:
  costs: 1000000000
  charged_margin: 0.02
  q1: 0.035
  median: 0.05
  q3: 0.07
  prior_year_income: 12000000000
  threshold: 10000000000
steps:
  - study_required: max(0, prior_year_income - threshold)
  - below_range: q1 - charged_margin
  - adjustment: (median - charged_margin) * costs
  - ire_on_adjustment: adjustment * 0.10
  - inside_case_adjustment: max(0, q1 - 0.04) * costs
expected:
  study_required: 2000000000
  below_range: 0.015
  adjustment: 30000000
  ire_on_adjustment: 3000000
  inside_case_adjustment: 0

Example 2: soya export, shipment-date quote or registered contract (a decision)

Agro Este S.A. exports 10,000 tonnes of soya to its parent's trading company abroad. Its invoices show G 2,500,000 a tonne. On the shipment date the quoted reference price is G 2,700,000 a tonne. It had agreed a fixed price with its buyer months earlier, when the quote was G 2,550,000 a tonne.

• Contract not registered. The reference is the shipment-date quote. Base addition: (2,700,000 less 2,500,000) × 10,000 = G 2,000,000,000; IRE at 10% = G 200,000,000.
• Contract registered with the DNIT before relying on it. The reference is the contract-date quote: (2,550,000 less 2,500,000) × 10,000 = G 500,000,000; IRE = G 50,000,000.
• The figure that decides it is whether the contract was registered: on these facts registration saves G 150,000,000 of IRE. The exports go on the DJI-Num 7 the month after shipment.

name: Soya export, shipment-date quote against registered contract, 2026
inputs:
  tonnes: 10000
  invoice_price: 2500000
  shipment_quote: 2700000
  contract_quote: 2550000
steps:
  - base_unregistered: max(0, shipment_quote - invoice_price) * tonnes
  - ire_unregistered: base_unregistered * 0.10
  - base_registered: max(0, contract_quote - invoice_price) * tonnes
  - ire_registered: base_registered * 0.10
  - saving: ire_unregistered - ire_registered
expected:
  base_unregistered: 2000000000
  ire_unregistered: 200000000
  base_registered: 500000000
  ire_registered: 50000000
  saving: 150000000

Ask the client first

1. The group chart: who holds more than 50% of whom, and who controls management, directly or indirectly.
2. Every operation with a foreign related party, and every domestic related-party operation where one side is exempt, out of scope or in a special regime; amounts by type.
3. Any counterparty in a low-tax country without an information-exchange agreement, in a free zone, or a maquila company, and whether the presumption can be rebutted.
4. Gross income of the previous fiscal year (G 10,000,000,000 test) and the IRE regime (SIMPLE and RESIMPLE do not file the study).
5. For exporters of soya, soya products, maize, rice or wheat: shipment dates, invoice prices, quotes and whether contracts were registered.
6. The year-end, the last digit of the RUC, and the authorised professional who will ratify the study.

Sources

Source	URL	Read on
Ley N° 6380/2019, BACN text: arts. 35 to 39 (valuation rules), arts. 8, 15, 21, 75	https://www.bacn.gov.py/leyes-paraguayas/9332/ley-n-6380-de-modernizacion-y-simplificacion-del-sistema-tributario-nacional	2026-11-11
Decreto N° 4644/2020, DNIT copy: arts. 2 to 32	https://www.dnit.gov.py/documents/20123/199761/Decreto+N%C2%B0+4644-2020.pdf/54a42ca3-8159-d73a-af7f-4a8986e66d31	2026-11-11
Decreto N° 7402/2022, DNIT copy: art. 2, new art. 5 of Decreto 4644	https://www.dnit.gov.py/documents/47797/47809/Decreto+N%C2%B0+7402-2022.pdf/8d9f9b0b-eaf7-3b21-04db-da09578fe74f	2026-11-11
Resolución General N° 115/2022, DNIT copy: arts. 2 to 13, 16, 17	https://www.dnit.gov.py/documents/20123/209148/RG+115_Por+la+cual+se+reglamenta+el+ETPT+y+otras+disposiciones+sobre+PT_VF.pdf/d1d362e5-9688-3876-4303-3fa62159636d	2026-11-11
Resolución General N° 134/2023, DNIT copy: arts. 1 and 2 (2022 and 2023 transitional filing by Mesa de Entrada; art. 9 of RG 115 otherwise applies)	https://www.dnit.gov.py/documents/20123/267216/RG+N%C2%B0+134_PRESENTACI%C3%93N+DEL+ESTUDIO+T%C3%89CNICO+DE+PRECIOS+DE+TRANSFERENCIA+Y+LOS+DOCUMENTOS+PROBATORIOS+DE+DESVIRTUACI%C3%93N+DE+LA+VINCULACI%C3%93N+PRESUNTIVA+CON+RESIDENTES+DEL+EXTRANJERO-1.pdf/e2d73135-23dd-c1b3-dc3e-02325d1f2a55	2026-11-11
DNIT, deadlines under Ley 6380 (RG 38/2020), read for the informative-returns calendar	https://www.dnit.gov.py/web/portal-institucional/w/vencimiento-ley-n-6380/19	2026-11-11
Ley N° 125/1991, DNIT copy of the 1991 text (scanned; arts. 170 to 179 read by OCR)	https://www.dnit.gov.py/documents/47797/47809/P+-+Ley+N%C2%BA+125-91.pdf/63cf3ff2-2b45-5920-cfc0-e562ff41ced9	2026-11-11

Not yet confirmed: whether the art. 38(7) commodity rule applies to exports to unrelated buyers (RG 86/2021, not read, regulates the DJI-Num 7 for all affected exporters); the current amount of the maximum contravención fine set by the Executive; the RG 96/2021 art. 4 documents needed to rebut the presumed relationship (not read); the RG 86/2021 rules on the DJI-Num 7 and the markets accepted as references (not read); whether the DNIT publishes a list of low or nil tax jurisdictions under Decreto 4644 art. 5; how the interquartile range is computed (the texts read do not set a quartile formula); any later resolution changing the RG 115/2022 filing months; the Spain convention's entry into force; whether Paraguay has country-by-country reporting rules.