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One More Compliance Burden in Paraguay 

27th January 2022

If you thought Paraguay’s tax authorities were finished when they released new transfer pricing guidance in December 2020—well, how can we put this gently—you were wrong. A December 30, 2021, resolution introduced additional rules. As you may recall, the 2020 guidance made very specific demands about transfer pricing analyses including trying the CUP method first; using comparable uncontrolled transactions that take place in the same fiscal year as the tested party transaction; and of course, using the inter-quartile range to determine arm’s length pricing. The 2021 resolution, however, mandates that transfer pricing professionals must register and prove their qualified to issue transfer pricing reports—as if you needed another compliance burden! Here’s the process: To qualify, tax executives must have at least four years of experience as a tax advisor or three years’ experience advising on international taxation or transfer pricing matters. You’ll also need an academic background in transfer pricing. Once you produce your CV, diploma, and judicial records, Paraguay’s tax administration will register you within 10 days. The good news is you won’t have to go through this process again for a while: The registration remains valid for three years.