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April 12, 2022

Paraguayan tax authority publishes requirements for preparing the 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 October 31, 2022. Taxpayers should prepare now for the filing.

In General Resolution No. 115/22 (issued April 07, 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 January 1, 2021, with the first TP report due in 2022, for the tax year ending December 31, 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 PYG 10 billion (approx. USD 1.5 million) must prepare and submit a TP report. Those that do not have gross income exceeding PYG 10 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 April 30, June 30 or December 31, 2021, the TP report is due October 31, 2022. For tax years ending April 30, June 30 or December 31, 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 April 8, 2022 and applies to tax year 2021 and onwards.


Contact Information
For additional information concerning this Alert, please contact:
Ernst & Young Paraguay - Auditores y Asesores de Negocios
   • Gustavo Colman (
   • Manuel Fernandez (
   • Ximena Gonzalez (
   • Sebastian A Acuña (
Ernst & Young US, LLP, Latin American Business Center, New York
   • Lucas Moreno (
   • Ana Mingramm (
   • Pablo Wejcman (
   • Enrique Perez Grovas (