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

Local contact

EY Global

29 Oct 2021
Subject Tax Alert
Categories Transfer Pricing
Jurisdictions Paraguay

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

On 14 October 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.


On 30 December 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 1 July 2021.

Decree No. 4644/20 also requires taxpayers to register the purchase-sale written agreements related to these transactions on 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 1 November 2021.

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

For additional information with respect to this Alert, please contact the following:

Ernst & Young Paraguay - Auditores y Asesores de Negocios, Asunción
  • Gustavo Colman 
  • Sebastian A Acuña 
  • Ximena Gonzalez 
  • Manuel Fernandez 
Ernst & Young LLP (United States), Latin American Business Center, New York
  • Lucas Moreno 
  • Ana Mingramm
  • Pablo Wejcman 
  • Enrique Perez Grovas 
Ernst & Young Abogados, Latin America Business Center, Madrid
  • Jaime Vargas 
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
  • Lourdes Libreros 
Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific
  • Raul Moreno, Tokyo
  • Luis Coronado, Singapore 

For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.