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October 28, 2021
2021-1969

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

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

On October 14, 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.

Background

On December 30, 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 July 1, 2021.

Decree No. 4644/20 also requires taxpayers to register the purchase-sale written agreements related to these transactions in 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 November 1, 2021. Additionally, Decree No. 6105/021 requires taxpayers to register their purchase-sale written agreements concluded before November 1, 2021 that are related to exports made after July 1, 2021 by December 31, 2021.

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Contact Information
For additional information concerning this Alert, please contact:
 
Ernst & Young Paraguay - Auditores y Asesores de Negocios
   • Gustavo Colman (gustavo.colman@py.ey.com)
   • Sebastian A Acuña (sebastian.acuna@py.ey.com)
   • Ximena Gonzalez (ximena.gonzalez@py.ey.com)
   • Manuel Fernandez (manuel.fernandez@py.ey.com)
Ernst & Young US, LLP, Latin American Business Center, New York
   • Lucas Moreno (lucas.moreno@lan.ey.com)
   • Ana Mingramm (ana.mingramm@ey.com)
   • Pablo Wejcman (pablo.wejcman@ey.com)
   • Enrique Perez Grovas (enrique.perezgrovas@ey.com)
 

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