Paraguay master file and local file requirements (2026)

What are Paraguay's latest transfer pricing rules?

Paraguay prices related party transactions on documented methods and makes you file the study behind them. The regime came in with the 2019 tax modernisation law^[1], promulgated on 25 September 2019, and a decree signed on 30 December 2020 brought it into force for fiscal years starting 1 January 2021. The tax authority publishes the filing rules^[2] that set the threshold, the deadlines and the fines.

The authority changed its name along the way. The Subsecretaría de Estado de Tributación, the SET, was merged with customs into the Dirección Nacional de Ingresos Tributarios, the DNIT, by a law promulgated on 4 August 2023, with the key provisions taking effect on 1 January 2024. The DNIT now runs tax and customs together^[3]. Older guidance still says SET.

Who has to file a transfer pricing study in Paraguay?

Corporate income tax payers whose prior year gross income passed PYG 10,000,000,000 and who traded across the border with a related party. So does any taxpayer dealing with a low or nil tax jurisdiction, a free zone user or a maquila counterparty, whatever the income, unless the presumed link is rebutted. Businesses taxed under Paraguay's simplified income tax regimes for small and medium enterprises are exempt.

Who counts as a related party in Paraguay?

Two parties are related when one directly or indirectly controls the management, the control or the capital of the other. The link is also presumed, with no ownership at all, when the counterparty is resident in a low or nil tax jurisdiction or uses a free zone or maquila regime. A foreign parent should assume its Paraguayan subsidiary is in scope the moment it trades with the group abroad.

That presumption is rebuttable. You file a communication that rebuts it, with the documents behind it, and the deadline for that falls earlier than the study.

Does Paraguay require a master file?

Not confirmed. No master file obligation was found in Paraguayan law at the last verification in October 2026. Paraguay belongs to the OECD and G20 Inclusive Framework on base erosion and profit shifting, which signals the three tier documentation philosophy, but nothing local has been enacted. The requirement, the threshold and the deadline are all unverified.

Two later resolutions from the tax authority, issued in 2024 and in 2026, were not reviewed and could change this. Prepare the technical study regardless, because that is the confirmed obligation today. Do not import another country's master file threshold as if Paraguay had enacted one.

Does Paraguay require country-by-country reporting?

Not confirmed. No country by country report and no notification rule appears in the verified Paraguayan sources. Applicability, threshold, filing deadline and notification are each unverified. Paraguay does appear on the OECD Inclusive Framework membership list^[4] updated on 5 December 2025, which signals alignment with the three tier standard but is not an enactment.

Do not assume the EUR 750 million consolidated group revenue figure used elsewhere applies here until the tax authority enacts and publishes it.

Which transfer pricing filings go to the tax authority?

Two. The technical study, the Estudio Técnico de Precios de Transferencia, goes in as a PDF with spreadsheets through the Marangatu system. The communication that rebuts a presumed related party link goes in separately and earlier. The tax authority published the filing format^[5] on 18 July 2023.

When is Paraguay transfer pricing documentation due?

In July of the year after a 31 December close, so the 2025 study is due in July 2026. The date moves with the fiscal year end, and the rebuttal communication always lands four months ahead of the study.

The resolutions behind this calendar may have been amended since, so confirm the current dates with the tax authority before you file.

What language and currency must the study use?

Not confirmed, so this page does not state a rule. No verified requirement on the language or the currency of Paraguayan transfer pricing documentation was found. In practice the study is filed to a Spanish language authority through the Marangatu system, which makes Spanish text and guaraní figures the safe working assumption. Check with the tax authority if a supporting document is in another language.

What are the penalties for getting Paraguay transfer pricing wrong?

A late rebuttal filing or a late informative declaration costs PYG 900,000. A late study, wrong figures in the study or missing supporting records draws the maximum contravention fine, which the Executive sets at the deadline rather than fixing in the text, so the exposure is not knowable in advance.

The penalty rule names that informative declaration by its form number only, and what the form covers is not confirmed, so read the label no further than it goes.

How does Paraguay price commodity exports?

On the public quotation, not on your own comparables. Where an exported good has a public international quotation, the export price has to match that market quotation on the shipment date. This is the precio de cotización rule, and regulation extended it to soy, soy derivatives, corn, rice and wheat for exports from 1 July 2021.

Paraguay is an export economy, so this is a live audit focus rather than a technicality. A group selling Paraguayan soy to its own trading arm abroad is tested against the quotation, whatever its benchmarking study says.

How does Paraguay differ from the OECD three tier standard?

Paraguay is not an OECD member and has no OECD transfer pricing country profile. It uses its own names, a technical study rather than a local file, and carries no confirmed master file tier and no confirmed country by country tier. It also adds the commodity quoted price rule, which the three tier standard does not have.

The statute sets seven valuation methods, broadly in line with the OECD toolkit, plus that quoted price rule for commodities. Whether Paraguay formally follows the OECD Transfer Pricing Guidelines is not confirmed, so the statute, not the Guidelines, settles how a method is applied.

How do multinationals comply with Paraguay transfer pricing rules?

The sequence for a foreign parent with a Paraguayan entity:

1. Check last year's gross income against PYG 10,000,000,000.
2. List every transaction with a company in your own group abroad: goods, services, royalties, loans and cost sharing.
3. Flag any counterparty in a low or nil tax jurisdiction, a free zone or a maquila regime. If the presumed link is wrong, file the rebuttal in March.
4. Pick a method for each transaction from the seven the statute allows, and price commodity exports off the public quotation instead.
5. Build the benchmarking that supports each method, and write down why that method fits.
6. File the technical study through the Marangatu system by July, as a PDF with its spreadsheets.

How we help with Paraguay transfer pricing

Paraguay files its study rather than keeping it, so the work has a hard date on it every year and an audit is not what triggers it. We test whether your entity crosses the threshold, build the comparables and the functional analysis, write the technical study and file it through Marangatu before the July date. See how our transfer pricing software works.

Book a demo to find out whether your Paraguayan entity crosses the PYG 10,000,000,000 threshold this year.