It is hereby established that it is mandatory to provide information to the DNIT regarding transactions conducted with cryptoassets.
General Resolution No. 48/2026
March 23, 2026
Due to system failures in Marangatú, the filing deadlines for final and informational tax returns have been extended on an exceptional basis.
General Resolution No. 49/2026
March 24, 2026
Provisions are established for the disclosure of information on earnings, reserves, and distributable earnings in the Notes to the Financial Statements of obligated taxpayers (Obligation 948).
► General Resolution No. 47/2026 – Obligation to report transactions involving cryptoassets.
The National Tax Revenue Directorate (“DNIT”) issued General Resolution No. 47/2026, dated March 10, 2026, establishing for the first time in Paraguay the formal obligation to provide information on transactions involving cryptoassets. The measure does not create a new tax, but rather an information reporting obligation aimed at strengthening transparency and tax oversight in a sector of growing economic importance.
The regulation broadly defines the concept of a cryptoasset, encompassing any digital representation of value based on distributed ledger technology (“blockchain”), including value tokens, utility tokens, stablecoins, and NFTs, among others. Digital currencies issued by central banks (“CBDCs”) and financial instruments regulated by securities market laws are excluded.
The following are required to file the Informative Affidavit on Cryptoassets (“DJI – Cryptoassets”): (a) the owners, administrators, or managers of cryptoasset platforms operating in the country; and (b) individuals, legal entities, and other entities resident or incorporated in the country that trade in cryptoassets, when the annual transaction amount exceeds USD 5,000, whether through non-resident platforms or without the intermediation of any platform.
The minimum required information includes, for each transaction: date and time, identification of the parties involved—or wallet addresses—type of cryptoasset, amount traded, gross value in dollars, fees, and the transaction hash. The filing must be made annually through the Marangatú System, within three months following the close of the fiscal year. The first filing will correspond to the 2026 fiscal year and must be submitted in March 2027 for taxpayers with a fiscal year-end of December 31.
Reportable entities must include Obligation 959 – DJI Cryptoassets in their RUC. Late filing will be penalized with a fine of ₲ 1,000,000 for non-compliance. It should be noted that the resolution is not retroactive.
If you would like to learn more, we have prepared a more detailed article, which you can find here.
► General Resolution No. 48/2026 – Exceptional extension of deadlines due to system failures at Marangatú.
On March 23, 2026, the Marangatú system experienced significant outages due to cuts in the fiber-optic network, which affected connectivity at the DNIT data center. The outage coincided with a day of high tax volume, with multiple filing deadlines scheduled for that day.
In response to this situation, the DNIT issued General Resolution No. 48/2026, which exceptionally extended the filing deadlines for final and informational tax returns from March 23 to March 24, 2026, in order to avoid harm to taxpayers who were unable to complete their filings on time.
According to Internal Revenue General Manager Éver Otazú, the system did not go down completely, but it did experience slowness and intermittent outages. Cuts were detected at two points in the fiber-optic network, allegedly linked to acts of vandalism, which were repaired during the day. This is not the first time the DNIT has faced this type of issue, as thefts of fiber-optic cables have also been reported on previous occasions.
► DNIT General Resolution No. 49/2026 – New requirements for disclosing information on profits, reserves, and distributable earnings in financial statements.
Through General Resolution No. 49/2026, issued on March 24, 2026, the DNIT ruled that Corporate Income Tax (“IRE”) taxpayers required to file financial statements under Obligation 948 must include in the Notes to the Financial Statements detailed information on the composition and allocation of retained earnings and accumulated results.
The measure applies to financial statements for periods ending on or after December 31, 2025, and aims to strengthen control mechanisms and transparency in the accounting information submitted to the tax authorities. Specifically, the Notes to the Financial Statements must contain, at a minimum: (a) a reconciliation of retained earnings (net income for the year, prior-period results, and adjustments); (b) an identification of distributable earnings; and (c) a breakdown of the allocation of earnings, including dividends distributed, capitalized earnings, established reserves, and amounts pending distribution.
If you would like to learn more, we have prepared a more detailed article, which you can find here.
Through Resolution No. 2, Minutes No. 12 dated March 12, 2026, the Central Bank of Paraguay (the “BCP”) approved the new General Regulation of Paraguay’s Payment Systems (SIPAP), introducing a comprehensive update to the regulatory framework applicable to payment systems in the country, in line with Law No. 7503/2025 on the National Payment System (the “Regulation”).
From a structural standpoint, the Regulation organizes the operation of SIPAP into four main components: (i) general rules; (ii) the regime applicable to the Central Securities Depository (DEPO); (iii) specific provisions for the Real-Time Gross Settlement System (RTGS), the Automated Clearing House (ACH), and the Instant Payment System (IPS); and (iv) the operational rules of the Instant Payment System (IPS).
One of the most relevant aspects of the update is the expansion of the scope of participants. The Regulation expressly includes capital markets entities and payment service providers, including those that initiate payments.
In addition, new tools are incorporated, such as the QR Hub and digital savings deposit certificates (CDA-d), which are part of the initiatives promoted by the BCP to modernize the financial infrastructure.
The new regulatory framework also strengthens participants’ obligations, particularly in relation to information security, risk management, business continuity, and fraud prevention. In this regard, entities are required not only to comply with more demanding technical and operational standards, but also to ensure the availability and efficiency of the payment services offered to users.
Through Resolution SS.SG. No. 031/2026 dated January 30, 2026 (the “Resolution”), subsequently expanded by Resolution SS.SG. No. 117/2026 dated March 23, 2026, the Superintendence of Insurance (the “SIS”) approved an update to the registration and license renewal regime for insurance intermediaries and loss adjusters, introducing relevant changes to the requirements, timelines, and conditions applicable to the performance of such activities in Paraguay.
Under the new regime, applications for registration and renewal must be submitted in accordance with the deadlines, periods, and conditions established by the SIS through its institutional web platform.
For this purpose, registration will be opened once per calendar year, subject to limited quotas defined in each call, while renewals may be opened four times per year. The opening periods will be communicated by Circular, and the authority will have up to sixty (60) calendar days from the closing of each period to decide on the approval or rejection of the applications.
All information and documentation submitted in connection with registration or renewal processes must be filed exclusively through the institutional platform and will be deemed to have the status of an affidavit, with the applicant being responsible for its truthfulness, accuracy, and completeness.
In addition, licenses will be valid for up to three (3) years, except in the case of first-time registration, where the SIS may establish a different term to align expiration dates with the renewal schedule.
As a new development, applicants are required to disclose, under affidavit and through the institutional platform, all digital profiles used for commercial purposes (including social media accounts, websites, or other digital channels), providing the corresponding links and confirming that no other profiles related to the regulated activity exist. Such profiles must be publicly accessible to allow monitoring by the authority, and any false, incomplete, or inaccurate information may result in the rejection of the application, without prejudice to applicable sanctions.
Additionally, through Resolution SS.SG. No. 117/2026, the SIS introduced transitional measures to facilitate the implementation of the new regime during the 2026–2027 period. Certain requirements are temporarily relaxed, allowing the submission of either surety bonds or professional liability insurance policies for agents and brokers, and deferring the requirement for valid licenses for signatories acting on behalf of legal entities until January 1, 2028.
Finally, the regulation provides that granted licenses may lapse one year after issuance if the agent, broker, or loss adjuster does not carry out activities related to the authorized business within that period, unless a duly justified reason is provided and accepted by the SIS.
Through Circular SV.SG. No. 002/2026 dated March 3, 2026 (the “Circular”), the Superintendence of Securities (the “SIV”) announced the expansion of the scope of its electronic registry platform known as the Agent Registration Tool (the “HRA”).
In particular, the Circular introduced two new procedures that must be processed through this platform:
the registration of issued and fully paid book-entry shares; and
the registration of book-entry shares for public offering.
It is worth noting that the implementation of this new modality does not introduce any changes to the documentary requirements established under the applicable Securities Market regulations. Accordingly, market participants must continue to comply with the relevant regulatory requirements for such filings, with the change being exclusively procedural in terms of the submission channel.
Additionally, the SIV issued a detailed guideline for agent registration, which outlines the process for submitting information, uploading documentation, and finalizing applications through the HRA system.
Finally, the Circular is currently in force, having become mandatory as of March 4, 2026.
Provisions are established regarding the information that IRE taxpayers must disclose in the Notes to the Financial Statements, in relation to earnings, reserves, and distributable earnings, effective as of the fiscal year-end on December 31, 2025.
► DNIT General Resolution No. 49/2026 – Establishes provisions for the disclosure of information regarding profits, reserves, and distributable earnings in the Notes to the Financial Statements.
Through General Resolution No. 49/2026, the National Tax Revenue Directorate (“DNIT”) established new reporting requirements for Corporate Income Tax (“IRE”) taxpayers who are required to file financial statements with the DNIT under Obligation No. 948.
The main objective of this regulation is to strengthen the control and audit mechanisms for the Dividend and Profit Tax (“IDU”), facilitating the DNIT’s reconciliation of the net worth reported by taxpayers with their actual operating economic reality. In this regard, the Notes to the Financial Statements are required to contain detailed information on the composition and allocation of retained earnings and accumulated results.
Minimum information required in the Notes:
The resolution provides that the Notes to the Financial Statements must include, at a minimum, the following information:
Reconciliation of retained earnings, detailing: the current year’s net income, retained earnings from prior years, and the corresponding adjustments.
Distributable earnings, identifying earnings for the current fiscal year and accumulated earnings from prior fiscal years.
Distribution or allocation of earnings, indicating dividends or earnings distributed, capitalized earnings, earnings allocated to reserves, and earnings pending distribution.
Composition of reserves (legal, optional, statutory, and other), reporting for each type: the opening balance, increases and decreases for the fiscal year, and the closing balance.
Additional details for each reserve: its purpose, the source of the earnings comprising it, the fiscal year(s) of generation, the accounting account linked to its use, the corporate body that approved its establishment, and the possibility of future distribution.
Effective Date and Filing:
The resolution applies to financial statements for fiscal years ending on or after December 31, 2025. This means that taxpayers under the General IRE Regime whose fiscal year ends on that date must comply with these new requirements when filing their financial statements through the Marangatu Tax Management System, as part of the documentation corresponding to Obligation No. 948.
Pursuant to General Resolution No. 38/2020, the standard deadline for filing financial statements for the fiscal year ending December 31, 2025, is April 2026, according to the filing schedule for Informative Tax Returns (between April 8 and 26, depending on the last digit of the taxpayer’s RUC). Notwithstanding this, it should be noted that in recent years the DNIT has granted exceptional extensions that pushed this deadline back to June; therefore, it is recommended to remain vigilant for the possible issuance of a similar resolution for this fiscal year.
Connection to the IDU:
It is important to note that this resolution falls within the context of IDU oversight, whose taxable event, pursuant to Article 40 of Law No. 6380/2019, is triggered by the distribution or payment of profits, dividends, or returns to owners, co-owners, partners, or shareholders. By requiring details on reserves and their potential for future distribution, the DNIT seeks to have more precise tools to verify that companies do not indefinitely defer the distribution of profits as a mechanism to postpone IDU payments.
In practice, this regulation introduces an additional reporting burden that taxpayers and their accounting advisors must consider when preparing the financial statements for the 2025 fiscal year, particularly regarding the traceability of the origin and destination of accumulated profits and the justification for the purpose of each reserve established.
Vouga Abogados fue distinguida como Paraguay Law Firm of the Year 2026 at the Chambers Latin America Awards, organized by Chambers and Partners, one of the most respected recognitions in the legal industry across the region.
The distinction was announced during the awards ceremony held in Mexico City, an event that each year brings together leading law firms from across Latin America to recognize those that have stood out for the quality of their work, the development of their practices, and their impact on the legal market.
Vouga Abogados receives this recognition for the seventh time, reflecting the consistency of its work and reaffirming its position as one of the leading law firms in the Paraguayan legal market, as well as the regional reach of its practice areas.
The selection of the Chambers Latin America Awards is based on the annual research conducted by Chambers and Partners for its regional guide, widely regarded as one of the most influential references in the legal market. Through this analysis, the awards recognize firms that have demonstrated outstanding performance, leadership within their jurisdiction, and a significant role in complex legal matters.
This recognition reflects the continued commitment of the Vouga Abogados team to professional excellence, as well as the trust that clients place in the firm to support them in their most important projects, transactions, and strategic decisions.
The obligation to provide information to the DNIT on transactions carried out with crypto assets is established, defining the obligated parties, the content of the informative affidavit, the deadlines for submission, and the penalties for non-compliance.
Development
► General Resolution No. 47/2026 – Establishes the obligation to provide information to the DNIT on transactions carried out with crypto assets.
Mediante la Resolución General N° 47/2026 («la “Resolución”), de fecha 10 de marzo de 2026, la Dirección Nacional de Ingresos Tributarios («DNIT») estableció la obligatoriedad de suministrar información relativa a todas las transacciones realizadas con criptoactivos. La norma se fundamenta en la creciente relevancia económica de este tipo de activos y en la necesidad de fortalecer las acciones de control, fiscalización y cumplimiento de las obligaciones tributarias.
La resolución define al criptoactivo como toda representación digital de valor o de derechos basada en tecnología de libro mayor distribuido («blockchain») o similar, que no es emitida ni garantizada por un banco central ni por una autoridad pública. El concepto abarca, entre otros, tokens de valor, tokens de utilidad, stablecoins y tokens no fungibles («NFTs»). Quedan expresamente excluidas las monedas digitales emitidas por bancos centrales («CBDCs») y los instrumentos financieros regulados por las leyes del mercado de valores.
Asimismo, la norma define de manera amplia el concepto de plataforma de criptoactivos, incluyendo a toda persona física, jurídica o entidad, protocolo informático o contrato inteligente que ofrezca servicios de emisión, intermediación, comercialización, intercambio, transferencia, custodia o administración de criptoactivos, ya sea de manera centralizada («CEX») o descentralizada («DEX/DeFi»). Se incluyen también billeteras digitales custodiales y no custodiales, marketplaces de NFTs, y plataformas de staking, lending o yield farming.
What transactions are covered by the resolution?
En cuanto a las transacciones alcanzadas, la resolución abarca prácticamente toda operación que involucre criptoactivos: emisión, creación («minting»), minería («mining»), intermediación, comercialización, intercambio, custodia, transferencias entre personas, utilización como medio de pago, participación en mecanismos de consenso, operación de nodos, y cualquier otra forma de disposición o transmisión de criptoactivos; incluso la tenencia de los mismos.
Who is required to file the declaration?
The parties required to file the Cryptoasset Informative Affidavit are: (a) the owner, administrator, or person responsible for cryptoasset platforms operating in the country; and (b) individuals, legal entities, and other entities resident or incorporated in the country that operate with crypto assets, when the annual amount of transactions exceeds five thousand US dollars (USD 5,000), either individually or jointly, and provided that they operate through non-resident platforms or without the intermediation of any platform.
The informative affidavit must be submitted annually, within the third month after the end of the fiscal year being declared, through the Marangatu Tax Management System. The obligation will be enforceable from the 2026 fiscal year for taxpayers with a closing date of December 31, and from the 2027 fiscal year for those with a closing date of April 30 or June 30. Obligated parties must request inclusion in the RUC (Unified Taxpayer Registry) of obligation 959-DJI Crypto Assets.
What must the return contain?
En cuanto al contenido de la declaración, la norma exige un nivel de detalle significativo. Por cada operación, deberá informarse, como mínimo: fecha y hora; identificación de los intervinientes («o, en su defecto, las direcciones públicas de billeteras o contratos inteligentes»); denominación, símbolo y red del criptoactivo; cantidad negociada hasta el décimo decimal; valor bruto en dólares americanos; comisiones y gas fees; y el hash de la transacción con las direcciones de origen y destino.
Los tipos de transacciones que deben informarse incluyen: compraventa, tenencia, intercambio entre criptoactivos, donaciones y transmisiones a título gratuito, transferencias hacia o desde plataformas y billeteras digitales, cesiones temporales o préstamos, pagos en especie, emisión y destrucción («burning»)de criptoactivos, y la obtención de rendimientos por actividades de minería, staking, lending u otras formas de generación de beneficios.
What are the penalties for non-compliance?
En materia de sanciones, la presentación fuera de plazo de la declaración jurada informativa será sancionada con una multa por contravención de un millón de guaraníes («₲ 1.000.000»), sin perjuicio de otras responsabilidades administrativas. Además, los sujetos que reúnan las condiciones y no se encuentren inscriptos en el RUC deberán registrarse para dar cumplimiento a la resolución.
Finally, the General Directorate of Tax Collection and Assistance and the General Directorate of Large Taxpayers of the General Internal Revenue Service will be responsible for monitoring the correct application of the provisions of the resolution.
It should be noted that this resolution represents a significant step in the tax regulation of crypto assets in Paraguay, aligning the country with international trends in fiscal transparency regarding digital assets. The breadth of the definitions adopted—particularly that of a cryptoasset platform, which covers both centralized and decentralized environments—and the level of detail required in the information to be reported reflect the DNIT's intention to obtain a comprehensive view of this market.
How does this relate to international tax information exchange?
Es fundamental tener presente que Paraguay se adhirió a la Convención de Asistencia Administrativa Mutua en Materia Fiscal, incorporada al ordenamiento jurídico por medio de la Ley N° 6.656/2020 («MAAC, por sus siglas en inglés»). En virtud de dicho tratado multilateral, la DNIT puede intercambiar información tributaria con aproximadamente 147 jurisdicciones participantes, a los efectos de combatir la evasión fiscal internacional. El MAAC prevé distintas modalidades de intercambio de información: a solicitud, espontáneo y automático. En particular, el artículo 6 del MAAC constituye la base jurídica internacional que habilita a los Estados parte a suscribir acuerdos multilaterales de autoridades competentes para instrumentar el intercambio automático de información sobre materias específicas. En este contexto, Paraguay se ha comprometido a iniciar sus primeros intercambios automáticos de información sobre cuentas financieras bajo el Estándar Común de Reporte («CRS»)en 2027, para lo cual deberá suscribir el correspondiente acuerdo multilateral de autoridades competentes («CRS-MCAA»)y adecuar su marco normativo interno. Este compromiso fue anunciado oficialmente durante la 17.ª reunión plenaria del Foro Global sobre Transparencia e Intercambio de Información con Fines Fiscales, celebrada en Asunción en noviembre de 2024.
La implementación de la Resolución General N° 47/2026 facilitaría significativamente la futura incorporación de Paraguay al Marco de Informe de Criptoactivos o Crypto-Asset Reporting Framework («CARF»), desarrollado por la Organización para la Cooperación y el Desarrollo Económico (“OCDE”)como un marco de transparencia fiscal específico y complementario al CRS, cuyo objetivo es el intercambio automático de información sobre transacciones con criptoactivos entre autoridades fiscales. El CARF se instrumenta a través de un acuerdo multilateral de autoridades competentes propio (“CARF-MCAA”), basado igualmente en el artículo 6 del MAAC. Con la Resolución General N° 47/2026, los contribuyentes y las plataformas comenzarán a familiarizarse con las obligaciones de reporte, la DNIT desarrollará la infraestructura tecnológica necesaria a través del Sistema Marangatu y el país contará con una base de datos que podría adaptarse al esquema XML estandarizado por la OCDE para el intercambio multilateral bajo el CARF. Si bien Paraguay aún no ha asumido un compromiso formal de implementación del CARF —a diferencia de Brasil, Colombia, Costa Rica y México, que ya se comprometieron a iniciar intercambios bajo este marco en 2027 o 2028—, la eventual adopción del CARF posicionaría a Paraguay como una jurisdicción comprometida con la transparencia fiscal internacional, reforzando su reputación ante el Foro Global y otros organismos internacionales.
General Resolution No. 47/2026 bears notable similarities to CARF requirements. The definitions of cryptoasset and cryptoasset platform adopted by the DNIT follow a conceptual line very close to that of the OECD standard, which also covers centralized and decentralized providers. Likewise, the level of detail required in the informative affidavit—including the identification of participants, wallet addresses, transaction hashes, and dollar values—corresponds to the information that the CARF requires to be reported to tax authorities. This convergence suggests that the resolution could be laying the technical and administrative groundwork for Paraguay's eventual accession to the CARF.
However, joining the CARF also poses specific challenges. First, Paraguay will need to sign the CARF-MCAA and adapt its domestic regulatory framework to enable the automatic exchange of information under this modality—similar to what it will need to do to implement the CRS. In turn, the increase in formal reporting obligations could generate significant compliance costs for a still-nascent local crypto ecosystem. It should be noted that the OECD has advanced a capacity-building strategy to support the widespread implementation of the CARF, with a modular approach that jurisdictions committed to the joint implementation of the CRS and the CARF can leverage. On balance, the benefits of moving toward greater tax transparency—both in terms of country reputation and enforcement capacity—outweigh the costs of adaptation, and General Resolution No. 47/2026 constitutes a first concrete and significant step in that direction.
Presentamos nuestra Guía práctica para crear y administrar sociedades en Paraguay – 2026, un documento diseñado para ofrecer una visión clara y accesible sobre los principales aspectos legales vinculados a la constitución y gestión de empresas en el país.
El material aborda los elementos fundamentales de las sociedades, los tipos societarios más utilizados en Paraguay incluyendo las Sociedades Anónimas (S.A.), Sociedades de Responsabilidad Limitada (S.R.L.), Empresas por Acciones Simplificadas (E.A.S.), sucursales de sociedades extranjeras y consorcios, así como aspectos clave de gobierno corporativo y funcionamiento societario.
Esta guía proporciona una explicación práctica del marco normativo aplicable y de las principales consideraciones que deben tener en cuenta emprendedores, inversionistas y empresas interesadas en establecer o desarrollar operaciones en Paraguay.
Para obtener más información sobre los temas abordados en esta guía o recibir asesoramiento especializado, no dude en ponerse en contacto con nuestro equipo: Perla Alderete (palderete@vouga.com.py), Camila Dutra (cdutra@vouga.com.py), Maura Velasquez (mvelazquez@vouga.com.py)
Regulates Law No. 7,424/2025, which creates the National Unified Registry and Cadastre System and the National Unified Registry ("RUN").
DNIT General Resolution No. 44/2026
February 20, 2026
Approves the new model contract for Vehicle Tracking Service Providers ("SSV"), replacing the model provided for in Annex VII of DNA Resolution No. 475/2023.
DNIT General Resolution No. 45/2026
February 20, 2026
The approval of companies providing vehicle tracking services through electronic seals ("SSV-PEMA") is renewed.
Non-Binding Consultation No. 791
December 2025
VAT withholding on logistics expenses that customs brokers bill their clients.
► Decree No. 5305/2026 – Law No. 7,424/2025 is regulated, creating the unified national registry and cadastre system and the unified national registry.
The Executive Branch has regulated Law No. 7,424/2025 through Decree No. 5305/2026, introducing significant advances in the implementation of the Unified National Registry and Cadastre System and the RUN. Although the regulation covers various technical aspects related to the operation of the registry and cadastre system, it also incorporates provisions of particular interest from a tax perspective, especially in terms of real estate appraisal and property tax assessment.
One of the central points of the decree is the consolidation of the role of the National Tax Revenue Directorate ("DNIT") within the new institutional framework. The regulation confirms that the DNIT will be responsible for key functions in the process of determining the tax value of real estate, including the issuance of real estate appraisal reports and the handling of claims related to such appraisals. This role is coordinated with the cadastral information provided by the RUN, creating a system of institutional cooperation aimed at improving the quality and updating of the data used for tax purposes.
Within this framework, the decree establishes that real estate appraisals will be determined by the Executive Branch by decree, based on technical reports prepared by the DNIT and cadastral information provided by the RUN. In turn, the DNIT is expected to design the appraisal system that will calculate the tax value of real estate, which will constitute the tax base for the settlement of real estate tax and its surcharges. These tax values must be used by municipalities for tax collection, without the possibility of modification by other public entities.
The regulations also introduce specific rules for updating and modifying tax assessments. In particular, it is expected that current assessments may be adjusted when the property's registry or cadastral information is updated. In such cases, the DNIT will calculate the new tax value based on the data provided by the RUN, and it will take effect from the fiscal year following the modification of the property. Likewise, the possibility of making counter-settlements is contemplated when a revaluation has been carried out late, although a maximum time limit of five years is established for such adjustments.
Another relevant aspect concerns the tax treatment of properties located in more than one municipal or departmental jurisdiction. The decree provides that when a property is simultaneously located within the territorial limits of two or more municipalities, the RUN must proceed to divide it in the registry into as many independent properties as there are jurisdictions involved. In exceptional cases where the property is indivisible, the property tax must be paid to the corresponding municipalities in proportion to the area occupied by the property in each jurisdiction and the tax value assigned to each portion.
Finally, the decree formalizes institutional changes related to real estate tax administration. In particular, it provides for the incorporation of the Real Estate Taxation Department, previously under the National Cadastre Service, into the structure of the DNIT, together with its staff and resources. This measure aims to centralize the functions related to the determination of tax value and to strengthen the tax administration's capabilities in the area of real estate taxation.
► DNIT General Resolution No. 44/2026 – The new model contract for Vehicle Tracking Service (“SSV”) providers is approved.
Through General Resolution No. 44/2026, dated February 20, 2026, the National Tax Revenue Directorate ("DNIT") approved a new model adhesion contract for the provision of Vehicle Tracking Services using Electronic Seals. This new model completely replaces the one provided for in Annex VII of Resolution DNA No. 475/2023.
Resolution DNA No. 475/2023 regulated the application and use of the Vehicle Tracking System ("SSV") used by the customs administration for the remote tracking of cargo covered by the customs transit regime within the national territory, by means of electronic seals. The purpose of this system is to strengthen the control and traceability of goods in transit, contributing to the prevention of irregularities and the security of the logistics chain.
The amendment responds to the need to update the terminology and adapt the contractual terms to the current institutional framework, considering that Law No. 7143/2023 created the DNIT, integrating the functions of the former National Customs Directorate (“DNA”). Pursuant to Article 23 of said law, any reference to the DNA should be understood as referring to the General Customs Management (“GGA”). Likewise, Article 14 of Decree No. 82/2023 provides that the regulations issued by the former DNA remain in force until they are amended or repealed by the DNIT.
In this context, the General Directorate of Customs Surveillance, through Note DGVA No. 16/2026, pointed out the need to update the contract model in order to ensure regulatory consistency, legal certainty, and the correct application of contractual instruments in the field of electronic seal services.
The resolution designates the General Customs Management (“GGA”) as the agency responsible for supervising, signing, and administering adhesion contracts for the provision of vehicle tracking services using electronic seals. This provision is relevant for foreign trade operators and VTS service providers, who must adjust their contractual relationships to the new approved model.
It should be noted that the vehicle tracking system is an essential tool in customs traffic control, as it allows the customs administration to monitor in real time the location and status of cargo traveling under this regime, ensuring that goods reach their destination without unauthorized deviations. The update of the membership agreement strengthens the legal framework for this operation and facilitates the adjustment of relations between the DNIT and service providers.
► DNIT General Resolution No. 45/2026 – Renewal of the approval of companies providing vehicle tracking services through electronic seals ("SSV-PEMA")SSV-PEMA”)
Through General Resolution No. 45, the DNIT ordered the renewal of the approval of certain companies providing vehicle tracking services through electronic seals, within the framework of the control system applicable to the customs transit regime.
The measure is part of the regulatory framework previously established for SSV through Electronic Customs Monitoring Seals ("PEMA"), a technological tool designed to strengthen the control and traceability mechanisms for cargo traveling under the customs transit regime within the national territory. Through this system, the customs administration can monitor in real time the movement of means of transport carrying goods under customs control, with the aim of safeguarding the integrity of cargo and reducing the risks associated with diversions or tampering.
In this context, the DNIT evaluated the applications submitted by companies that were already providing this service and verified compliance with the technical and operational requirements demanded by current regulations. As a result of this validation process, the approval of the companies Nivel 7 S.A., Sky Cop Paraguay S.A., AJ Consultoría S.A., and Phi Omega Satelital S.A. was renewed, authorizing them to continue operating as providers of vehicle tracking services using electronic seals.
The resolution also authorizes the signing of the corresponding model contract between the administration and the approved companies, an instrument that formalizes the continuity of the service provision under the conditions established by the applicable regulations.
► Non-Binding Consultation No. 791 – VAT withholding on logistics expenses that customs brokers bill their clients.
In December 2025, the DNIT issued a ruling in the context of a non-binding consultation analyzing the treatment of Value Added Tax ("VAT") applicable to certain logistics expenses invoiced by customs brokers to their clients, particularly in the context of operations related to exporters in the meatpacking sector.
The consultation focused on determining whether such logistics expenses could be considered part of the service provided by the customs broker and, consequently, benefit from the exemption from the VAT withholding regime provided for in the current regulations. In particular, it was questioned whether the exemption established for customs brokers' fees should apply when they bill their clients for certain costs associated with the logistics of the operations.
In analyzing the issue, the tax administration made a distinction between the customs broker's own service and activities related to international logistics. While the customs broker's service focuses on managing the customs procedures necessary for the import or export of goods—including the preparation and submission of documentation, tariff classification, and tax settlement—logistics activities cover tasks such as transportation, storage, cargo consolidation, and coordination with shipping companies or airlines, among others.
Although in practice customs brokers may coordinate or manage these services as part of a broader service offering to their clients, the DNIT considered that such activities are not part of the customs broker's own mandatory service within the framework of customs processing. Consequently, the logistics expenses invoiced by these professionals cannot be considered part of their fees for customs clearance services.
Based on this analysis, the administration concluded that the exception provided for in the regulations for customs brokers' fees does not apply to logistics expenses. Therefore, when these items are billed to clients, the VAT withholding regime must be applied in accordance with the general rules.
The General National Budget for fiscal year 2026 is approved, setting budget limits for credits for undue or excess payments and for interest and surcharges.
DNIT General Resolution No. 43/2026
January 30, 2026
The rotation system for External Tax Auditors (AEI) is modified, establishing a maximum limit of three consecutive fiscal years for signing opinions for the same taxpayer.
Binding Consultation
No. 788
December 2025
Treatment of tax credits in the event of a partial spin-off.
Binding Consultation
No. 785
December 2025
Deductibility of life insurance taken out abroad.
► Law No. 7609/2025 – The General National Budget for fiscal year 2026 is approved.
On December 31, 2025, the Executive Branch enacted Law No. 7609, approving the General National Budget ("PGN") for fiscal year 2026. The budget amounts to G. 149.6 trillion (equivalent to approximately USD 18.995 billion), representing an increase of 12.3% over the budget for fiscal year 2025. The macroeconomic projections on which the PGN is based estimate a 3.8% growth in Gross Domestic Product (GDP) and 3.5% inflation for 2026.
The PGN complies with the fiscal deficit ceiling of 1.5% of GDP, as established by the Fiscal Responsibility Law (Law No. 5098/2013). This fiscal discipline framework is relevant for taxpayers, as it defines the limits within which the State can assume spending and investment commitments.
In terms of taxation, the PGN Law contains provisions that directly impact taxpayers, particularly with regard to budgetary limits for the crediting of amounts for undue or excess payments, VAT refunds to non-profit entities ("ESFL"), and interest and surcharges arising from tax credit recovery processes. These budgetary limits represent the maximum amounts that the National Tax Revenue Directorate (DNIT) can credit during the fiscal year for the items indicated.
This is a budgetary measure that has been implemented every year since Law No. 5061/2013, which provided for it in Article 7, and Decree No. 850/2013. The overall limits represent the maximum total amount that the DNIT can credit for each item throughout the fiscal year, while the individual limits per taxpayer prevent a single taxpayer from monopolizing a disproportionate percentage of the available credits. This means that no taxpayer can represent a percentage of credits greater than that established, thus preventing one taxpayer from excluding the others.
If the total budget limits are reached during the fiscal year, the amounts pending credit are deferred to the following fiscal year without generating legal accessories. The area responsible for making the credits must correlatively record the resolutions that provide for them, for inclusion in the PGN for the following fiscal year.
In addition, the budget law contains other provisions of general interest, such as budget allocations by state institution, projected revenues, planned investments, and sources of financing. The complete document can be consulted on the website of the Ministry of Economy and Finance (www.mef.gov.py).
► DNIT General Resolution No. 43/2026 – The rotation system for External Tax Auditors is modified.
Through General Resolution No. 43/2026, dated January 30, 2026, the DNIT amended Article 12 of General Resolution No. 30/2019 —updated by RG DNIT No. 15/2024— which regulates Article 33 of Law No. 2421/2004 "On Administrative Reorganization and Fiscal Adjustment," referring to the Registry of External Tax Auditors ("AEI").
The amendment establishes a mandatory rotation rule for the signing auditor. Under the new wording, the auditor signing the External Tax Audit Report may not sign such a report for the same taxpayer for more than three (3) consecutive fiscal years. In order to sign opinions for the same taxpayer again, at least two (2) fiscal years must have elapsed since the last opinion was signed.
The taxpayer remains free to hire the AEI of their choice, provided that it is duly authorized by the Tax Administration. The restriction applies specifically to the signing auditor, not to the audit firm or company, which allows the contractual relationship with the firm to remain in force as long as a different signatory is appointed.
The established rotation will be calculated starting in fiscal year 2026, in accordance with the provisions of Article 2 of the resolution. This means that fiscal years prior to 2026 are not counted for the purposes of calculating the three consecutive years allowed.
This measure is in line with international auditing principles that promote auditor independence and periodic rotation as a mechanism to prevent conflicts of interest and strengthen the objectivity of opinions. For taxpayers subject to the external tax audit requirement—based on their annual turnover—it is advisable to plan in advance for the transition of the signing auditor in order to avoid inconveniences when filing the audited financial statements.
The resolution was signed by the National Director of Tax Revenue, Óscar Alcides Orué Ortíz, following a favorable opinion from the General Directorate of Legal Advice (Opinion DGAJ-CSJ-DTJ No. 15 of January 30, 2026).
► Binding Consultation No. 788 - Treatment of tax credits in the event of a partial spin-off.
The DNIT issued its response to a binding consultation made in the context of a corporate reorganization process. A company mainly engaged in livestock farming submitted a binding consultation to the DNIT to confirm whether, in the event of a partial spin-off, the accumulated tax credits could be transferred to the resulting companies in proportion to the assigned equity. Specifically, the Tax Administration was asked to rule on the possibility of transferring these credits up to the limit of the spun-off assets, allowing for their total or partial reorganization in the new entity.
The authority's conclusion was clear: in spin-off processes, VAT tax credits may be transferred to the successor companies in proportion to the net assets actually transferred with respect to the total net assets of the predecessor company. It was also established that the transferable amount may not exceed the value of the spun-off assets, which acts as a maximum limit. Thus, it is expressly recognized that spin-offs—as a form of corporate reorganization—enable the proportional transfer of tax credits.
To reach this conclusion, the Administration started from the recognition that spin-offs constitute a form of corporate reorganization, along with mergers and corporate transformations. Based on this understanding, it recalled that the VAT regime provides that, when transfers of assets occur as a result of a reorganization, the tax credit of the predecessor may be transferred to the successor in proportion to the net assets transferred. In turn, such transfers are exempt from tax, which reinforces the tax neutrality of the reorganization process.
► Binding Consultation No. 785 - Deductibility of life insurance taken out abroad.
Through a binding consultation process, a taxpayer subject to personal services income tax filed a binding consultation with the DNIT to clarify whether premiums paid for life insurance taken out abroad could be considered a deductible expense for tax purposes. The appellant argued that this expense should be allowed as deductible, on the understanding that it was related to the health concepts covered by the regulations.
The Administration concluded that expenses for life insurance taken out abroad are not deductible for IRP-SP purposes. This criterion is based on the fact that current regulations expressly limit the deductibility of expenses incurred outside the country to those exclusively related to education and health, categories that do not include life insurance.
To support this position, the authority recalled that the tax law allows the deduction of certain personal expenses, even when incurred abroad, provided that they are directly related to the taxable activity and correspond exclusively to education or health. The regulations also specify what is meant by these concepts, listing payments for professional fees, supplies, medicines, and other expenses directly related to these purposes.
In this context, the DNIT analyzed the legal nature of life insurance and emphasized that its main purpose is to cover risks associated with the death or survival of the insured, which differentiates it from health insurance. As it is not expressly provided for within the deductible concepts and cannot be assimilated to the health expenses defined by the regulations, the expenditure does not meet the requirements for deduction.
