Category: Uncategorized

Executive Summary

June 2025
Regulation			Date	Content
Decree No. 4299			July 24, 2025	Incorporation into Paraguayan law of the new model for authorization certificates for quotas from the Southern Common Market (“Mercosur”).
Binding Consultation No. 701			June 2025	Issuance of electronic tax documents by the absorbing company with respect to invoices issued by the absorbed company, following a merger by absorption.
Binding Consultation No. 705			June 2025	Issuance of a single unnamed electronic self-invoice by financial institutions, on a monthly basis and for a lump sum, for those transactions in which the beneficiaries of payments are not required to issue invoices.
Binding Consultation No. 707			June 2025	Possibility of transferring or not transferring the remaining Value Added Tax ("VAT") credit among the members of a consortium if it is dissolved.
July 2025
Regulation			Date	Content
General Resolution N° . 32/25			22 de julio de 2025	The National Tax Revenue Directorate, (“DNIT”) regulated the procedures for applying special provisions and tax benefits for Sports Events of International Relevance (“EDRI”).
General Resolution No. 33/25			July 31, 2025	The DNIT clarified the validity of the registration of Persons Linked to Customs Activities ("PVAA") in the category of "Occasional Importer" and modified the requirements and conditions for PVAA authorization and renewal .
General Resolution No. 34/25			July 31, 2025	The DNIT modified the regulations for registration in tax identification number ("RUC"), data updates, and cancellations.

JUNE – 2025:

► Decree No. 4299/2025 - The new Mercosur quota authorization certificate model is incorporated into Paraguayan law.

Mercosur, as a regional integration bloc, has trade agreements with several countries, including Colombia and Israel. In this context, Resolution GMC No. 31/2010 was issued, approving the current "System for the Administration and Distribution of Quotas Granted to Mercosur by Third Countries or Groups of Countries" (“SACME”) in its Annex I, while approving the distribution of quotas for the Agreements with Colombia and Israel in its Annexes II and III, respectively.

In order to make the SACME operational in the day-to-day practice of international trade operators, a model certificate of authorization of Mercosur quotas was provided as Appendix I thereto, as well as a certificate of cancellation of Mercosur quotas as Appendix II. The model in Appendix I was updated by Resolution GMC No. 31/2010, incorporated into Paraguayan law by Decree No. 4299/2025.

This new model for the Mercosur quota authorization certificate introduced the flag of the issuing State Party as additional information on the document and also advanced its method of signature, which changed from handwritten to digital with authentication methods such as barcodes and QR (quick response) codes, in line with the technological advances experienced to date in international trade.

Although Resolution GMC No. 31/2010 itself stipulated that Paraguay should have incorporated it into its legal system before December 30, 2024, this was only accomplished on July 31, 2025, with the publication of Decree No. 4299/2025 in Official Gazette No. 171, at which point this process was completed.

► Binding Consultation No. 701 – Response from the DNIT on the possibility of the absorbing company issuing electronic tax documents for invoices issued by the absorbed company after a merger by absorption.

The DNIT recently clarified that, in merger by absorption processes (which could be extended to any type of merger), there is no legal impediment for the absorbing company to issue complementary documents—such as credit or debit notes—in reference to invoices previously issued by the absorbed company.

The DNIT's conclusion is based on the legal framework established by the Civil Code, which provides that, in cases of merger, the absorbing company succeeds the absorbed company in all its rights and obligations without the need for liquidation. Thus, it is also incumbent upon the acquiring company to issue tax documents reflecting refunds, discounts, rebates, or uncollectible credits related to transactions invoiced by the acquired company.

The challenge of the issue lay in the fact that both merged companies were electronic invoicers and that the Integrated National Electronic Invoicing System ("SIFEN") only allows credit and debit notes to be linked to invoices issued by the same taxpayer. To overcome this limitation, the Tax Administration confirmed that an update to SIFEN is being developed that will enable reference to the merged RUC when generating complementary electronic documents, which will be implemented through the respective technical note.

In the meantime, and in order not to interrupt the commercial operations of the electronic invoicing companies involved in the merger, the DNIT authorized a contingency mechanism: the issuance of complementary documents in physical format, provided that they are subsequently registered in the Marangatu Tax Management System ("SGTM"), in accordance with current regulations. Once the respective SIFEN update is available, companies must cancel these physical stamps and adapt to the new modality.

This clarification is key for companies involved in reorganization processes, as it ensures that tax obligations can be met without generating conflicts due to the issuance of electronic documents in the context of a merger. It also sets a precedent in the interaction between the electronic invoicing regime and the concepts of business reorganization, anticipating a technological adaptation that will facilitate future operations.

► Binding Consultation No. 705 – Response from the DNIT on the issuance of a single unnamed electronic self-invoice by financial institutions, on a monthly basis and for a lump sum, for those transactions in which the beneficiaries of payments are not required to issue invoices.

The DNIT confirmed that financial institutions will be able to issue electronic self-invoices to document transactions in which the counterparty does not issue tax receipts, such as interest payments on savings, debt securities, contributions to public entities, or certain commissions abroad. The aim is to provide legal certainty and transparency to a significant volume of transactions that, until now, lacked adequate tax support.

Financial institutions face a recurring difficulty: a large part of their expenses—for example, interest paid to savers or contributions to the Deposit Guarantee Fund—do not have invoices issued by the counterparty. This creates gaps when it comes to complying with tax reporting obligations and the Tax Administration's audit processes.

Since these items are exempt from VAT, the lack of documentation does not directly affect the collection of this tax, but it does make it difficult to trace and control expenditures in the system.

The DNIT ruled that, as purchasers, banks may issue electronic self-invoices with consolidated amounts for monthly periods, recording interest payments and other relevant disbursements, without identifying any particular counterparty in the header, since the document would cover transactions with several counterparties. These self-invoices will allow transactions to be formally documented without the need for the beneficiary to issue receipts.

Until specific regulations governing this procedure are issued within the framework of SIFEN, the monthly balance sheet reported to the Central Bank of Paraguay will be accepted as valid documentation, provided that it identifies the counterparties to the transactions, thus compensating for the lack of identification of counterparties in the monthly electronic self-invoice with consolidated amounts.

The decision is based on Law N° 6380/2019 (the "Tax Law"), which regulates the requirements for sales receipts, and Decree N° 6539/2005, which defines self-invoicing as a valid document provided that it has a tax stamp. Likewise, Decree No.° 872/2023 incorporated self-invoicing into the electronic invoicing system, specifying that it is the purchaser's responsibility to document transactions with parties that are not required to issue receipts.

The measure provides banks and financial institutions with a practical and legal mechanism to support high-volume and economically significant transactions. At the same time, it guarantees the DNIT better control over this type of transaction.

In the short term, the monthly balance sheet will continue to be valid as a supporting document, but the goal is for electronic self-invoices to become the standard tool for tax documentation of these transactions going forward.

► Binding Consultation No. 707 – DNIT response on the possibility of transferring or not transferring the remaining VAT tax credit among the members of a consortium if it is dissolved.

The DNIT clarified that, upon dissolution of a consortium, the remaining VAT tax credit cannot be transferred or distributed among its members. This balance can only be used within the consortium itself, either by offsetting it against the tax liability of the tax itself or, failing that, by computing it as a cost or expense for the determination of Corporate Income Tax ("IRE").

Consortiums formed for the execution of public works are considered independent taxpayers for VAT and IRE purposes. This means that they must keep their own accounts, issue receipts, file tax returns and, in the event of liquidation, complete a full accounting and tax closure before requesting the cancellation of their RUC.

At that stage, the consortium must settle all its tax obligations, and any remaining balance that is not used is extinguished upon dissolution. This is supported by the Tax Law, which expressly states that in no case is VAT credit refundable due to the closure or termination of the taxpayer's activity, except for exceptions provided for in the same regulation.

This means that companies that are members of a consortium in liquidation will not be able to receive a proportional share of the remaining VAT tax credit, since that right belongs exclusively to the consortium as a taxpayer.

This clarification by the DNIT provides certainty on a sensitive issue in the reorganization and liquidation of consortiums: VAT tax credits are not transferable to partners and must be absorbed in full in the accounts of the entity that is being dissolved.

JULY – 2025:

► General Resolution No. 32/25 – Regulation of procedures for the application of special provisions and tax benefits for EDRI.

Through General Resolution DNIT N° 32/25, the DNIT established the procedures and requirements for the application of tax benefits and special customs regimes for EDRI events held in Paraguay. This resolution aims to regulate the provisions of Law N° 7467/2025, which creates a legal framework to attract, promote, and regulate these events.

The regulation seeks to simplify procedures for "Organizing Entities" and other beneficiaries participating in events declared as EDRI by executive decree. In this regard, the resolution recognizes two groups of subjects, subdivided into four groups of beneficiaries, as follows:

The resolution specifies that exemptions from income tax and VAT on income received in connection with EDRI (including the transfer of audiovisual broadcasting and marketing rights) apply to beneficiaries of Law No. 7467/2025, provided that they are associated with EDRI in the following ways:

1. Organizers: Identified in the decree declaring the EDRI.

2. Participants: Identified in a list issued by the National Sports Secretariat ("SND").

In these cases, the decree declaring an EDRI, plus the list issued by the SND that includes the participants, where applicable, will be the documents that justify the non-withholding of taxes by local withholding agents, who must keep a copy of them in their tax files.

The regulations also authorize the entry into the country of equipment, devices, and other items related to the EDRI under the temporary admission regime, with exemption from fees, contributions, and guarantees. For the application of this regime, a detailed list of those goods must be submitted, which must be approved by the SND.

In addition to all this, the procedure to be followed to make effective the exemptions for definitive imports and donations of goods affected by EDRI is also regulated. To this end, the SND must first validate the list of goods to be imported for EDRI, or its extension, the introduction of which must be authorized by resolution of the General Customs Management ("GGA").

After that, the legal representative or authorized third party of the Organizing Entity or applicable entity may request tax clearance certificates or authorization to make the tax-free donation through the SGTM. Applicants must have an "Active" RUC and be up to date with their tax obligations, declare the official import dispatch number to the GGA, and attach the relevant documents in ".pdf" format.

The DNIT undertakes to review applications within a maximum of 20 business days. Notifications regarding the status of the application will be sent through the "Marandu" Electronic Tax Mailbox and the email address registered with the RUC.

During the analysis of applications, the DNIT may request clarifications, additional information, or documents, which will suspend the deadline for resolving applications. If the applicant does not comply with these requirements within 10 business days, the application will be considered abandoned and will be archived.

► General Resolution No. 33/25 – The DNIT clarified the validity of the registration of persons linked to customs activities ("PVAA") in the category of "Occasional Importer" and modified the requirements and conditions for the authorization and renewal of PVAA.

General Resolution DNIT No. 33/25 establishes modifications to the regulation of the PVAA registry. This new regulation clarifies the validity of the registry for the category of "Occasional Importer" and expands certain requirements for the authorization and renewal of PVAA in general.

Among the main changes, the resolution clarifies that authorization for "Occasional Importer" will be valid until December 31 of the year in which the authorization is granted, in all cases, and not only for those who do not operate in the domestic market and whose RUC is in "Canceled" status.

In addition, the documentation requirements for the PVAA registration or renewal process have been expanded:

• Individuals: In all cases, they must attach a scanned copy of their identity document, including both sides (front and back), signed at the bottom of the document. The file must be in "*.pdf" format.

• Legal entities: Only once, the first time they apply for authorization or renewal (whichever comes first), they must attach a scanned copy of the identity document of the principal legal representative. This document must also include both sides (front and back), be signed by the representative, and be submitted in ".pdf" format.

► General Resolution No. 34/25 – Modifications for registration in the RUC, data updates, and cancellation.

General Resolution DNIT N° 34/25 has amended General Resolution N° 79/2021, which regulates registration, data updates, and cancellation in the RUC. This new regulation seeks to coordinate the RUC and the PVAA registry to ensure traceability and adequate control of customs operations, maintaining the integrity of the national tax system.

The resolution establishes changes in the requirements for cancellation of the RUC, incorporating compliance with customs obligations for this purpose. It also updates the annexes with the documents required for registration and data updates, providing mechanisms for the incorporation of representatives who will operate in the customs field and within the framework of the PVAA registry.

Main changes and key points:

• Requirements for RUC cancellation: In addition to the requirements already in place, the following have been added: (i) being up to date with the payment of customs obligations, which includes not having any outstanding customs tax settlements or guarantees; and (ii) not having any customs or legal proceedings pending, such as unfinished import or export processes, or actions before the contentious-administrative jurisdiction.

• Required documentation: Identity documents of individuals and representatives (legal or conventional) must now be scanned, signed by the applicant at the bottom, and attached in "*.pdf" format, compressed in a "*.zip" file in the SGTM. Files must be legible, clear, complete, and, in the case of identity documents, include both sides.

• Effective date of the regulation: The amendments for the cancellation of the RUC will take effect on May 1, 2026. The other provisions of the resolution, including updates to the annexes, took effect the day after their publication.

Executive Summary

		March 2025
		Regulation	Date	Content
		Executive Order No. 3465	March 11, 2025	Modifying the structure of the rules for the registration of persons involved in customs activities.
		Decree N° 3473	March 11, 2025	Incorporation to the Paraguayan legal system of the amendments to the specific requirements of the Mercosur Regime of Origin ("ROM") for certain codes of the Mercosur Common Nomenclature ("NCM").
		Decree No. 3593	March 26, 2025	The Executive Power empowered the Ministry of Economy and Finance ("MEF") to incorporate to the national legal system the directives of the Mercosur trade commission approving temporary reductions of import tariffs.
		Decree No. 3594	March 26, 2025	Incorporation to the Paraguayan legal system of the extension of the expiration of the export benefits between Mercosur and Bolivia.
	General Resolution N° 26		March 24, 2025	The National Directorate of Tax Revenues ("DNIT") regulated the enrollment in the Purchasing Tourism Regime ("RTC").
	General Resolution No. 27		March 31, 2025	The DNIT provided administrative measures related to the application of the RTC .
	General Resolution No. 29		March 31, 2025	The deadline for filing the financial statements corresponding to the fiscal year ended December 31, 2024 was exceptionally extended.

April 2025
Regulation		Date	Content
Law No. 7459		April 14, 2025	Modifying the rules for the calculation and payment of the municipal vehicle tax in all municipalities of the country.
Law No. 7467		April 24, 2025	Special tax rules are provided for Sports Events of International Relevance ("EDRI") and for the entities that organize them.
	Decree No. 3814	April 25, 2025	Incorporation to the Paraguayan legal system of the accumulation of origin in Mercosur and Bolivia of materials coming from Colombia, Ecuador and Peru.

May 2025
	Norm	Date	Content
	General Resolution No. 30/2025	May 06, 2025	The DNIT established the requirements and conditions for the qualification, renewal and update in the registry of persons linked to the customs activity through the Marangatú Tax Management System ("SGTM").
	General Resolution No. 31/2025	May 27, 2025	The DNIT established the criteria for the classification of goods included in Chapter 87 of the NCM, on land vehicles; their parts and accessories.

MARCH - 2025:

► Decree No. 3465/2025 - The structure of the rules for the registration of persons related to customs activity is modified.

By means of Decree No. 3465, the Executive Power modified key aspects of Decree No. 4672/2005, which regulates the Customs Code. Essentially, what Decree No. 3465 did was to modify Article 17 of the Annex to Decree No. 4672/2005 ("Customs Code Regulations"), which establishes the basis for the registration of persons related to the customs activity, delegating its establishment to the DNIT and repealing the rest of the articles (18 to 97) of the Customs Code Regulations on this matter.

For those who are linked to the customs activity, this implies that, from now on, all persons involved in this sector must register and keep their data updated according to the requirements, guidelines and conditions established by the DNIT, which has been empowered to regulate this registration and clearance, with the indication of incorporating technological advances to optimize the process.

This measure is taken in line with the powers of the DNIT, which, according to Law No. 7143/2023, is the body in charge of applying the customs legislation, collecting taxes, controlling the traffic of goods and setting standards for administrative procedures, among other functions. The autonomy granted to the DNIT allows it to issue these regulations.

► Decree No. 3473/2025 - Modifications to the specific requirements of the ROM for certain NCM codes are incorporated into the Paraguayan legal system.

The ROM is an essential aspect of the customs integration process among the Mercosur member States, since it establishes the requirements for a product, within its respective classification in the NCM, to be classified as originating in Mercosur and, therefore, not to be subject to the Common External Tariff ("CET") and, therefore, to be imported into the corresponding State without payment of customs duties, unless it is included in a National Exception List ("NEL") that allows it.

In view of this, the ROM, as well as the NCM, undergoes constant changes and updates, one of them being the one that occurred in CCM Directive No. 54/2024, which was incorporated into the national legal system by Decree No. 3473/2025.

Details of the amendments to the ROM, by NCM code, can be consulted in the annex to Decree No. 3473/2025, which is available here.

► Decree No. 3593/2025 - The Executive Power empowered the MEF to issue resolutions that incorporate to the national legal system the directives of the Mercosur trade commission approving tariff reductions on imports, on an exceptional and transitory basis.

By means of Decree No. 3593/2025, the Executive Power empowered the MEF to implement resolutions to incorporate the directives of the Mercosur Trade Commission. This will allow the application, on an exceptional and transitory basis, of import tariff reductions for those products not included in a LNE.

This initiative seeks to expedite the implementation of temporary tariff reductions previously approved for Paraguay by the Mercosur Trade Commission. The measure is part of Mercosur Resolution GMC No. 49/2019, which allows States Parties to temporarily reduce the CET in situations where it is necessary to ensure the normal and fluid supply of products. Paraguay had already incorporated this resolution to its national legal system through Decree No. 3631/2020.

The MEF, in its role as a member of the National Section of the Mercosur Trade Commission, will now be able to issue these resolutions more efficiently due to their transitory nature. This decision has the approval of the Ministry of Foreign Affairs, the Ministry of Industry and Commerce, and the DNIT.

► Decree No. 3594/2025 - The extension of the expiration of export benefits between Mercosur and Bolivia is incorporated to the Paraguayan legal system.

One of the main trade agreements, if not the main one, is the Economic Complementation Agreement ("ACE 36") of 1996, with its multiple annexes, which has been constantly updated through the respective protocols. ACE 36 contains, among other things, a trade liberalization program between the Mercosur States and Bolivia, as well as rules for the regime of origin and export incentives that allow a total tax exemption for imports between the signatories.

In article 19 of ACE 36 it was agreed that, initially, its trade liberalization program would apply to products that incorporate in their manufacture inputs imported temporarily or under the draw-back regime until 2001, with these types of products not being covered by such benefits since 2002. This term was extended several times by successive protocols, the last one being the Thirty-fourth Protocol, incorporated into the Paraguayan legal system by Decree No. 3594/2025.

According to this protocol, in force bilaterally between Paraguay and Bolivia since April 24, 2025, the trade liberalization program for the products mentioned in the previous paragraph will now be extended until August 7, 2028, which will cease to be benefited from the following day. Thus, the benefits of ACE 36 for such products were extended for almost 3 more years, since the previous expiration date had been set for December 31, 2024 by the Thirty-first Protocol.

► General Resolution No. 26/2025 - DNIT regulated the registration in the RTC.

Through General Resolution DNIT No. 26/2025, the DNIT regulated the registration in the RTC, in which those taxpayers who wish to avail themselves of the benefits of this special regime for the liquidation of the Value Added Tax ("VAT") on the importation and commercialization of certain goods destined to tourists must previously register. For a detailed explanation of the RTC, please click here and here.

Among the general requirements for the subjects of the RTC, taxpayers must be up to date with their tax obligations, have an active RUC and declare at least one local bank account for the transfer of funds. They must also attach the Certificate of Labor Compliance from the IPS and a certification from the Ministry of Industry and Commerce stating that they are not maquiladora companies, importers with benefits under the raw materials regime or beneficiaries of certain incentive laws.

Importers, traders and intermediaries have additional specific requirements, which, in general, mirror the provisions of Decree No. 2063/2024. Thus, for example, importers must attach bank statements showing an average operating turnover according to their integrated capital, and submit financial statements for the last 2 fiscal years to prove a minimum of 2 years in the commercial circuit. In case of not complying with the antiquity, a bank guarantee of USD 25,000 will be required. Merchants, on their part, must declare the address of their commercial establishment in one of the designated border cities.

Regarding intermediary companies, there are no specific requirements in Decree No. 2063/2024, which established the RTC. However, General Resolution No. 26/2025 added 2 requirements, one formal and one operational: the articles of incorporation or equivalent certification for Simplified Joint Stock Companies, and bank statements verifying an average monthly operational turnover of USD 100,000 or more in the last quarter, must be attached.

The same taxpayer may apply for registration in the 3 categories of subjects: importer, trader or intermediary; providing that only the strictest requirements must be complied with when the requirements for several categories overlap. Thus, for example, when a taxpayer simultaneously applies for registration as an importer and intermediary, it must comply only with the requirements for importers.

Depending on the category of the taxpayer, the application for registration will be verified by the General Directorate of Collection and Taxpayer Assistance or the General Directorate of Large Taxpayers. The DNIT has a term of 10 working days to approve the application and issue the Registration Certificate in the RTC, which will be valid for 2 calendar years.

Taxpayers operating in the RTC will have a term of 10 business days to communicate any modification of the information declared for this regime, applying the maximum fine per contravention (currently Gs.1,530,000) for late communications. This is in stark contrast with the general regime for updating data before the Single Taxpayer Registry ("RUC"), for which the deadline is 30 business days, with a fine per violation of Gs. 50,000 for late communications.

Once registered in the RTC, the affected taxpayers will become information agents and must comply with obligations 947 "Tax Audit" and 923 "Tourism Regime", the latter serving for the presentation of the quarterly reports required by the regime, which may subsist even after the exit from the RTC, until the inventory affected to it is exhausted.

► General Resolution No. 27/2025 - The DNIT provided administrative measures related to the application of the RTC.

The DNIT issued General Resolution DNIT N° 27/2025, establishing new administrative measures for the application of the RTC. This resolution is key for importers and traders operating under this regime in border cities such as Asunción, Ciudad del Este, Encarnación, Pedro Juan Caballero, Pilar and Salto del Guairá.

It provides that importers who registered under the previous Decree No. 1931/2019 and its amendments, and whose registration/renewal certificate expired on March 31, 2025, may continue their customs operations until April 30, 2025.

It is essential that within this period taxpayers manage the renewal of their registration under the new RTC established in Decree No. 2063/2024. They must follow the renewal procedure indicated in General Resolution DNIT No. 26/2025 to obtain the necessary authorization and be able to continue performing customs operations as from May 1, 2025.

► General Resolution No. 29/2025 - The deadline for the submission of financial statements for the fiscal year ended December 31, 2024 was exceptionally extended.

The DNIT has established an exceptional extension for the filing of Financial Statements. This measure applies to taxpayers of the Corporate Income Tax ("IRE") that pay it under the General Regime, whose fiscal years closed on December 31, 2024.

With this resolution, the time limit to file these reports went from April to June 2025, according to the termination number of each taxpayer's tax identifier in the RUC. With this measure, the DNIT seeks to lighten the burden of taxpayers and avoid non-compliance that may result in tax penalties.

It is important to note that this extension is of an exceptional nature. The deadlines for filing the Financial Statements of IRE taxpayers with closing date in April and June 2025 remain unchanged, and they must file them until August and October 2025, respectively.

For the schedule of due dates of the Informative Affidavits (DJI), please refer to article 6 of General Resolution SET N° 38/2020.

APRIL - 2025:

► Law No. 7459/2025 - The rules for the calculation and payment of the municipal vehicle patent tax in all municipalities of the country are modified.

The tax resources of the country's municipalities are composed of a great variety of taxes, fees and contributions. One of these is the annual vehicle tax, which is a partial property tax levied on the owners of vehicles, motorized or not, by the sole fact of their possession or ownership, in the municipality in which such owner has his domicile or establishment.

Until recently, this meant the coexistence of two different tax regimes for vehicle licenses: that of Asunción, governed by Law No. 881/1981 (as amended by Law No. 5817/2017), and that of the other municipalities, governed by Law No. 620/1976 (as amended by Law No. 7447/2025). Thus, while in Asunción this tax was between 0.5% and 0.25% of the taxable value in Customs, depending on the age of the vehicle; in the other municipalities it was between 8 and 0.5 minimum wages, depending on the category and age of the vehicle.

This generated a clear tax competition between Asunción and the other municipalities in terms of vehicle licenses, with the other municipalities being more beneficial for new high-end vehicles, while Asunción was friendlier for used and low-end vehicles. This distortion caused by the different taxation schemes was finally eliminated by Law No. 7459/2025, which unified the taxation of vehicle licenses in all municipalities of the country.

Although the form in which Law No. 7459/2025 was proposed may generate confusion in those who read it, the fact is that it fixed the vehicle license tax in all the municipalities of the country (including Asunción) at 0.3% of the taxable value provided by the National Traffic and Road Safety Agency ("ANTSV"), which will decrease by 0.015 percentage points until the tenth year, as from which the tax will be 0.15%, which is half of what corresponds to new vehicles.

► Law No. 7467/2025 - Special tax rules are provided for EDRIs and for the entities that organize them.

Law No. 7467/2025 established special provisions to attract, promote and regulate the development of EDRIs in Paraguay, and to create a specific legal regime in order to guarantee the necessary conditions for their organization and execution with the standards required for this type of events. Within this framework, the aforementioned law also provided the following tax benefits for EDRIs, their organizers and other persons related, linked, subsidiaries, members and/or affiliated to them:

1. Exemption of taxes on the importation of equipment, apparatus, articles and sports implements to be used in EDRIs.

2. Enabling of a special regime of temporary admission for all types of equipment, apparatus, articles and sports implements, as well as all promotional material to be used in the event, which will be free from the payment of taxes, contributions, fees or guarantees.

3. Exemption from all taxes on the transfer or importation of goods admitted under the special temporary admission regime when they are donated to the National Sports Secretariat or to national or international sports entities recognized by it.

4. Exemption of taxes on services rendered in connection with the importation or temporary admission referred to above.

5. Exoneration of taxes on the importation of articles related to the organization and development of the EDRI, listed in article 8 of Law No. 7467/2025, in the amounts and for the time fixed by the DNIT.

6. Exemption from Income Taxes and VAT on the income received by the organizers and participants of the EDRI, for their performance as such; including the assignment of audiovisual transmission and commercialization rights.

In order for a sporting event to be recognized as an EDRI and give rise to the application of the benefits listed above, it must be declared as such by a decree of the Executive Power. So far this year, there have already been 4 EDRI declarations, instrumented in Decrees N° 3770/2025, 3892/2025, 3909/2025 and 4219/2025, issued for the FIFA Congress, the Pan American Games Jr. 2025, the Paraguay Rally and the World Skate Games 2026, respectively.

► Decree No. 3814/2025 - Incorporates into the Paraguayan legal system the cumulation of origin in Mercosur and Bolivia of materials coming from Colombia, Ecuador and Peru.

Within the framework of ACE 36 between the Mercosur States and Bolivia, Annex 9 establishes the rules of origin that will allow them to implement a total tax exemption for imports between the signatories. Article 7 of this Annex established the rule of "cumulation" of origin, according to which materials originating in one signatory party that are incorporated into other merchandise in the territory of another signatory party will be considered as originating in the latter signatory party.

Additionally, the referred article foresaw the possibility of extending the "accumulation" of origin to third countries members of the Latin American Integration Association ("ALADI") with which the two signatory parties of ACE 36 that intervene in a specific operation have entered into a free trade agreement that exempts the materials in question; subject to each party taking the necessary actions to do so.

Thus, what was originally foreseen as a declaration of "best efforts" of the signatory parties of ACE 36, was materialized in the extension of the "cumulation" rule to materials originating from Colombia, Ecuador and Peru with the Thirty Third Protocol, subject to the rules of the Andean Community for cumulations in Bolivia, and to the respective Economic Complementation Agreements (N° 72, 59 and 58) signed with them by the Mercosur States for cumulations in Mercosur.

This cumulation with Colombia, Ecuador and Peru is effective as of July 24, 2025. It is subject, within the framework of the respective agreements, to the condition that the materials coming from these countries (1) comply with their origin regime; (2) have reached the 100% preference level, without quantitative limits; (3) have a definitive origin requirement; and (4) are not subject to differentiated origin requirements based on agreed quotas.

MAY - 2025:

► General Resolution No. 30/2025 - The DNIT established the requirements and conditions for the qualification, renewal and update in the registry of persons linked to the customs activity through the SGTM.

By means of General Resolution DNIT No. 30/2025 new requirements and conditions are established for the qualification, renewal and update in the Registry of Persons Linked to the Customs Activity in the DNIT ("PVAA" or "PVAA Registry", depending on whether it refers to the subjects or the registry). This measure seeks to modernize and simplify processes, promoting transparency and efficiency in customs operations.

The regulation integrates the technological tools of the General Customs Management ("GGA") and the General Internal Revenue Management ("GGII"). This is expected to reduce time and costs in the management of procedures for the PVAA.

In order to be included in the PVAA Registry, taxpayers with an active RUC must comply with certain requirements. Among them, they must be up to date with their formal obligations and have their RUC updated and in "Active" status. In addition, they must not have expired guarantees or customs liquidations, nor disciplinary sanctions before the GGA. The authorization request is made through the taxpayer's profile in the SGTM, attaching the required documentation in digital format, a list of which can be found in the annex to General Resolution DNIT No. 30/2025, by clicking here.

The GGA will be in charge of approving or rejecting the applications within a maximum period of 10 business days. Once approved, the status of PVAA will be reflected in the updated RUC. For certain types of PVAA that require homologation of their electronic information transmission systems, the approval will be finalized once the homologation is completed. It is important to note that the GGA may request additional information, and failure to provide it within 5 business days will result in the rejection of the application.

For those persons who do not have a RUC, the DNIT will grant an identifier in "Canceled" status if they wish to be enabled in the PVAA Registry for customs operations. International transport companies, occasional importers, diplomats and embassies must manage their authorization through the options available on the DNIT website. If a PVAA with RUC "Canceled" decides to operate in the domestic market, it must update its status to "Active".

The renewal of the authorization in the PVAA Registry will be annual and will follow a calendar established according to the termination of the RUC, being its authorization in force until the last day of said month, according to the following:

This opens the possibility that certain authorizations in the PVAA Registry, such as the first one made or renewals made after the expiration date, may be valid for more than 1 year, and up to 2 years, inclusive, depending on the interaction between the date of registration and the expiration month foreseen for the year following such registration.

The updating of data in the PVAA Registry is mandatory within 30 working days following any modification, and failure to comply with this term could generate a fine of G. 50,000; matching this to what is foreseen for RUC updates.

The documentary requirements established in General Resolution DNIT No. 30/2025 come into force on the first day of the following months: (1) August 2025 for importers (all categories) and customs brokers, and (2) May 2026 for other PVAA. Qualifications granted prior to these dates will be valid until the last day of the months indicated.

For further information on the PVAA Registry, you may consult the exclusive section that the DNIT has dedicated to this matter by clicking here.

► General Resolution No. 31/2025 - The DNIT established the criteria for the classification of goods included in chapter 87 of the MERCOSUR Common Nomenclature ("NCM"), which deals with land vehicles; their parts and accessories.

The DNIT has issued General Resolution DNIT No. 31/2025, which establishes the criteria for the classification of goods of Chapter 87 of the NCM -motor vehicles, tractors, velocipedes and other land vehicles; their parts and accessories- and the application of the corresponding tariff levels for their importation. The objective is to provide greater transparency and predictability to operators dealing with the importation of these goods.

The need to set differentiated criteria to classify goods of Chapter 87 of the NCM is due to the fact that, as from Decree N° 5822/2016, different tariff levels were established, depending on whether or not a vehicle corresponding to one of its headings is classified as a "used good", since to this type of good the ROM allowances would not apply and they would be subject to tariff level provided in the Annex of Decree No. 8015/2022, which is substantially higher than that of their "new" counterparts.

To this end, General Resolution DNIT No. 31/2025 incorporates specific fields in the computer system so that, at the time of the Detailed Import Declaration, it is precisely indicated whether the vehicle is "Recently Manufactured" (Yes/No) and "Unused" (Yes/No).

The resolution defines the following key terms:

1. Recently Manufactured Vehicle: The year of manufacture or model must match the year of the Import Clearance or be up to one year earlier.

2. Vehicle of non-recent manufacture: The year of manufacture or model is two years or more prior to the year of Import Clearance.

3. Unused vehicle: It has not been used since its manufacture or its rolling does not exceed 150 kilometers. Exceptionally, if it exceeds 150 km due to transfers from the manufacturing plant to the point of shipment or Customs, it must be accredited with a certificate from the manufacturer or assembler that includes chassis number, kilometers traveled and commercial invoice.

4. Vehicle in use: It has been used since its manufacture and its mileage exceeds 150 kilometers, without complying with the exception mentioned for vehicles not in use.

5. Year of Manufacture: Date of manufacture of the vehicle (from January 1 to December 31 of the respective year).

6. Model year: Commercial version assigned by the manufacturer, which may coincide with the calendar year of manufacture or the following year, and must be specified in the commercial invoice, catalogs or certificates.

Vehicles that simultaneously meet the criteria of "recently manufactured" and "unused" will be considered new. On the other hand, used vehicles shall be considered those that meet the criteria of "not recently manufactured" or "with use", or both, which shall be subject to the tariff levels of Decree No. 8015/2022.

A curiosity present in General Resolution DNIT No. 31/2025 is the double criterion used to classify vehicles as "recently manufactured" and "not recently manufactured", according to the age of their (i) year of manufacture or (ii) model year. This opens the possibility that unused vehicles that were manufactured up to 3 years prior to their release may be classified as "recently manufactured" if their model year corresponds to the year prior to the year of release (e.g.: release of 2025 on a vehicle with model year of 2024 and year of manufacture of 2023).

La Dirección Nacional de Propiedad Intelectual (“DINAPI”) presentó oficialmente las primeras Directrices para el Examen de Marcas en Paraguay (“Directrices”), con el apoyo del programa AL-INVEST Verde financiado por la Unión Europea. El documento unifica criterios para la evaluación de solicitudes de registro, armonizando la práctica nacional con la Ley Nro. 1294/98 de Marcas, su reglamentación y estándares internacionales.

Estas Directrices buscan reforzar la transparencia, previsibilidad y seguridad jurídica en el procedimiento marcario, ofreciendo una guía práctica para examinadores, profesionales y titulares de marcas.

Entre los lineamientos más relevantes se destacan:

• Signos admisibles como marca

Incluyen signos visibles (denominativos, figurativos, mixtos, patrones, combinaciones de colores, marcas tridimensionales, marcas de posición, de movimiento, hologramas y multimedia) y no visibles (sonoros). No se admiten actualmente marcas olfativas, gustativas o táctiles por falta de medios técnicos.

• Criterios sobre distintividad de la marca

La falta de distintividad es causa de rechazo. Se analiza considerando el signo, los productos o servicios solicitados y la percepción del público pertinente.

• Signos que no pueden funcionar como marcas

Genéricos: términos o elementos de uso común que designan el producto o servicio.

Descriptivos: signos que indican características, calidad, cantidad, destino, valor, lugar de origen u otras cualidades.

Engañosos: signos que pueden inducir a error sobre la naturaleza, calidad, origen u otras características.

Contrarios a la ley, orden público o moral: incluyen expresiones ofensivas, discriminatorias o prohibidas por normativa.

• Consideraciones para reconocer un derecho oponible

Incluyen la doble identidad, riesgo de confusión, notoriedad previa, indicaciones geográficas, nombres comerciales, denominaciones sociales, nombres de dominio, modelos o dibujos industriales y obras protegidas por derecho de autor.

• Protección que se otorga a los signos notoriamente conocidos

Serán protegidos aun sin registro en Paraguay, si son conocidos en el sector pertinente. La protección se extiende a productos o servicios no similares cuando exista riesgo de dilución, daño al prestigio o aprovechamiento injusto del renombre.

La Oficina considerará esta marca tal como se usa en el comercio en el país.  

• Sobre los registros solicitados de mala fe

Se rechazan solicitudes presentadas con intención deshonesta, como aprovechar la reputación ajena, bloquear a un competidor o causar perjuicio.

Según la DINAPI, el carácter dinámico de estas directrices permitirá su actualización periódica, asegurando que el examen de marcas en Paraguay se mantenga alineado con los desafíos del comercio y la innovación global.

Para acceder al contenido detallado de las Directrices haga click here.

Para obtener más información respecto de alguno de los temas abordados, por favor póngase en contacto con nuestros expertos: Manuel Acevedo (macevedo@vouga.com.py); Laura Lezcano (llezcano@vouga.com.py); Grecia Florentín (gflorentin@vouga.com.py); Stephanie Medina (smedina@vouga.com.py) 

Through Resolution No. 31, Minute No. 22 dated May 29, 2025, the Central Bank of Paraguay (“BCP”) approved the Guidance on the Management of Climate-Related Financial Risks for Supervised and Regulated Financial Intermediation Entities (“Risk Management Guide”). This regulation, which becomes mandatory as of January 1, 2026, sets forth guidelines aimed at strengthening the national financial system’s capacity to address the challenges arising from climate change.

The Risk Management Guide explicitly recognizes that climate risks, both physical and transitional, can translate into traditional financial risks such as credit, market, liquidity, operational, strategic, and reputational risks. In this regard, the BCP has adopted a macro and microprudential approach aligned with best international practices, particularly those established by the Basel Committee on Banking Supervision.

Regulated entities must integrate climate-related financial risks into their policies, governance structures, internal control frameworks, and comprehensive risk management systems. Among the most relevant aspects of the Risk Management Guide are:

1. Climate Governance: The board of directors of each entity must be actively involved in the management of these risks, approving specific policies, assigning responsibilities, and ensuring continuous training on climate risks.
2. Climate Risk Management: Entities are required to identify, measure, mitigate, and monitor their exposure to climate risks, incorporating these aspects into the credit cycle, portfolio management, risk concentration analysis, and strategic decision making.
3. Climate Stress Testing: Entities must develop internal capabilities to design and conduct climate scenario analyses and stress tests, considering their business model, complexity, and operational scale.
4. Data Infrastructure: Entities will be required to collect and use accurate, detailed, and up to date data to properly assess the potential impacts of climate change on financial operations.
5. Disclosure: Entities must adopt a formal climate-related disclosure policy, approved by the board, which includes governance, strategy, and risk management components.

With this guide, the BCP establishes a milestone in the integration of environmental sustainability into the country’s financial regulation. The regulation is expected not only to enhance the resilience of supervised entities to extreme climate events, but also to promote responsible financing practices aligned with global climate change commitments.

Through Resolution No. 5, Minute No. 25 dated June 19, 2025, the Central Bank of Paraguay (“BCP”) approved the extension of the Regulation establishing Minimum Standards for Good Corporate Governance (the “Regulation”), expanding its application to entities supervised by the Superintendency of Securities.

Through Resolution No. 5, Minute No. 25 dated June 19, 2025, the Central Bank of Paraguay (“BCP”) approved the extension of the Regulation establishing Minimum Standards for Good Corporate Governance (the “Regulation”), expanding its application to entities supervised by the Superintendency of Securities.

The Regulation sets out specific guidelines in the following areas:

• Board Responsibilities: The board is responsible for the entity’s strategy, risk management, organizational culture, and the overall oversight of corporate governance. It must ensure an adequate organizational structure and promote ethical conduct at all levels.
• Control Culture and Ethical Conduct: Entities are required to implement clear policies for the prevention of conflicts of interest, adopt codes of ethics, and establish mechanisms for resolving internal conflicts.
• Strategic Objectives and Corporate Values: Entities must have a strategic framework approved by the board, aligned with their risk appetite, and ensure its communication and enforcement throughout the organization.
• Information Technology (“IT”): Entities must establish adequate policies and structures for IT management, with a particular focus on security, regulatory compliance, and support for strategic decision-making.

As a result of this extension, Title 27 of the General Regulation of the Securities Market, which previously regulated this matter only partially for securities market entities, has been repealed. The previous framework is now replaced by a consolidated and unified version, applicable to all entities supervised by the BCP’s Superintendencies.

On June 27, 2025, Law No. 7503/2025 "On the National Payment System" was enacted, fully replacing the former Law No. 4595/2012. This new legislation marks a significant shift in the regulatory framework for payment systems in Paraguay, significantly expanding the supervisory scope of the Central Bank of Paraguay (BCP).

Unlike the previous framework, Law 7503/25 include as potentially regulated entities those that were previously outside the BCP’s direct supervision, such as:

• Payment gateways

• Payment processors

• Electronic money issuers

• Payment service providers (PSPs)

• Other actors in the payments ecosystem

The BCP is currently drafting specific regulations for Payment Initiation Service Providers (PISPs), with the aim of formally incorporating financial technology entities (fintechs) as authorized players in the ecosystem. This process also includes updating the requirements and operational rules that govern such services.

• Key highlights of Law 7503/25:

Establishes a comprehensive legal framework for the organization, supervision, and operation of the National Payment System.2. Introduces guiding principles such as security, interoperability, financial inclusion, and transparency.3. Grants the BCP powers to regulate, register, supervise, and sanction participants.4. Extends the scope to include non-traditional financial entities offering payment-related services.

• What does this mean?

Although the law has not yet been specifically regulated, its broad drafting allows the BCP to determine through resolutions who will be subject to it. Reports already indicate that the BCP is requesting information and compliance from companies previously outside formal oversight.

• Who may be affected?

Technology companies, fintechs, e-commerce platforms with proprietary payment gateways, e-money issuers, and other entities involved in the payments cycle may be affected by this new legislation.

• Registration and authorization

• Technical and security requirements

• Transparency and access rules

• Reporting obligations

At Vouga Abogados, we closely monitor regulatory developments in the sector and offer our legal team’s assistance to:

• Provide updated information on the implementation of the new law.

• Conduct preventive legal assessments on the applicability of the regulation.

• Assist in preparing compliance strategies in response to potential BCP requirements.

For more information or to schedule a meeting, feel free to contact us.

La Dirección Nacional de Propiedad Intelectual (DINAPI) avanza en la modernización del marco legal aplicable al diseño industrial en Paraguay. Actualmente, la materia se rige por la Ley N° 868/81 “De Dibujos y Modelos Industriales”, pero se encuentra en elaboración un nuevo proyecto de ley que busca actualizar y adecuar esta normativa a los desafíos actuales del entorno creativo y tecnológico.

Este trabajo se realiza junto con la Oficina de Propiedad Intelectual de la Unión Europea (EUIPO), en el marco del programa AL INVEST Verde DPI, con el apoyo técnico del consultor internacional Laurent Manderieux.

Entre las propuestas destacadas del borrador se incluyen:

• El cambio de denominación a “Diseños Industriales”.
• La inclusión de animaciones como posibles objetos de protección.
• Nuevas disposiciones alineadas con estándares internacionales.

El anteproyecto ya fue presentado en jornadas de trabajo con representantes de DINAPI, del ámbito académico y de los gremios de agentes de propiedad intelectual. Próximamente se habilitará un espacio virtual para recibir comentarios y sugerencias de todos los interesados. Por ejemplo, el tema de las tasas aún no ha sido abordado, ya que se encuentra en proceso de revisión interna. Los plazos y detalles de la consulta pública serán anunciados oficialmente por DINAPI.

Esta iniciativa representa un paso clave hacia una normativa más moderna, que fortalezca la protección de las creaciones y acompañe el desarrollo del sector productivo nacional.

Para obtener más información respecto de alguno de los temas abordados, por favor póngase en contacto con nuestros expertos: Manuel Acevedo (macevedo@vouga.com.py); Laura Lezcano (llezcano@vouga.com.py); Grecia Florentín (gflorentin@vouga.com.py); Stephanie Medina (smedina@vouga.com.py) 

			December 2024
			Regulation	Date	Content
			Law No. 7408	December 30, 2024	2025 Budgetary limits for the National Directorate of Tax Revenues ("DNIT") to credit amounts for undue or excess payments, interest and surcharges.
			Decree No. 3165	December 23, 2024	Real estate tax values for the taxable base of the real estate tax and its additions, corresponding to fiscal year 2025.
		Law No. 6380		September 25, 2019 (Update)	Validity of the limit for withholdings on account of Value Added Tax ("VAT") for local suppliers.
	January 2025
	Norm			Date	Content
		Decree No. 3237		January 16, 2025	Relaxation of the requirements for importers under the Buying Tourism Regime ("RTC").
		Decree No. 3108		December 19, 2019 (Update)	Percentage of guarantees to be submitted for the accelerated VAT refund regime by 2025.
		General Resolution DNIT N° 01		January 12, 2024 (Reminder).	Legal entities that register as new taxpayers in the Single Taxpayer Registry ("RUC") must issue their vouchers only electronically.
February 2025
Rule				Date	Content
		Decree No. 3339		February 10, 2025	Incorporation to the Paraguayan legal system of the extension to the limit of changes in the lists of national exceptions to the Common External Tariff ("CET") of the Southern Common Market ("Mercosur").
		Decree No. 3379		February 21, 2025	Incorporation into the Paraguayan legal system of the amendments to the Mercosur Common Nomenclature ("NCM") and its corresponding CET.

DECEMBER - 2024:

► Law No. 7408/2024 - The 2025 budget limits are established for the DNIT to credit amounts for undue or excess payments, interest and surcharges.

Law No. 7408/2024 approved the General Budget of the Nation ("PGN") for fiscal year 2025 and, with it, established several tax measures that, to a greater or lesser extent, affect taxpayers. One of these measures (Articles 235 and 236 of the PGN) are the annual budgetary limits for crediting taxpayers for balances due to:

1. for undue or excess payment,
2. VAT refunds purchased from non-profit entities ("ESFL"), and for accessories in the following recovery processes
3. for accessories in the following tax credit recovery processes:
   • VAT refund (exporters, export freight forwarders, Yacyretá suppliers, etc.),
   • repetition due to undue or excess payment and
   • refund of VAT purchased from the ESFLs.

This is a budgetary measure that has been implemented every year since Law No. 5061/2013 (see Article 7) and Decree No. 850/2013. For this fiscal year 2025 the overall and individual (per taxpayer) budget limits are the same as for fiscal years 2023 and 2024, being the following:

The global limits represent the maximum amount that DNIT can credit in the indicated concepts during the whole fiscal year 2025, while the individual limits per taxpayer are 30% of the global limit for each concept. This means that no taxpayer may represent a higher percentage of credits than indicated, thus avoiding that only one taxpayer excludes the others.

These budgetary limits do not apply to VAT refunds purchased from NPOs as a result of court rulings, as these have their own limits. Furthermore, the way in which this concept is credited to NPOs also differs from the normal regime, since these amounts are paid in cash, and not with credit to the taxpayer's current tax account, as occurs in the other cases.

In the event that the budgetary limits are reached during the fiscal year, the amounts pending crediting are deferred to the following fiscal year without generating legal accessories (interest, etc.). The area responsible for making the credits must correlatively record the resolutions that provide for them, for their inclusion in the PGN of the following fiscal year.

► Law No. 6,380/2019 - Seeks to extend the validity of the limit for VAT withholdings on account for local suppliers (UPDATE).

Law No. 6380/2019 ("Tax Law") introduced several short and medium term novelties to the national tax regime. One of them was the limit for VAT withholdings on account, provided for in the first paragraph of its Article 136. This limit was set at 10% of the tax stated in the sales receipt.

The Tax Law provided for the application of such limit as from the fourth year of its effectiveness, and due to the fact that the Tax Law became effective on January 1, 2020, the date for the implementation of the withholding limit was set for January 1, 2023. In other words, the application of this withholding limit was deferred from 2020 to 2023.

This decrease in the withholding percentage has great consequences for taxpayers that are VAT withholding agents, since they must adjust their systems to the new limit. Among such taxpayers are the following:

In addition to the withholding limit, the second paragraph of article 136 of the Tax Law provided for the progressive reduction of the percentage of VAT withholding on account as from the year following the effective date of the Tax Law and until the deadline for applying the withholding limit is met, i.e., from 2021 to 2022.

However, this progressive reduction was conditioned to the issuance of a decree of the Executive Power providing the schedule for such purpose, but since this did not happen, the withholding limit should have been in force all at once, without any progressive adjustment. Moreover, in Article 275 of Law No. 6873/2022, Article 287 of Law No. 7050/2023 and Article 285 of Law No. 7228/2023, which approved the PGN 2022, 2023 and 2024, respectively, the decrease was suspended for those years; which, curiously, was replicated again for this 2025 with Article 261 of Law No. 7282/2023, which approves the PGN for that fiscal year.

The inclusion of this suspension in the laws of the PGN 2023 to 2025 appears as an error that may generate confusion among individuals, since it refers to a rule that is no longer in force for those years, because the progressive decrease was a transitory provision that could only be implemented from 2021 to 2022, but no longer from 2023, since from then on it no longer makes sense, because the withholding limit is applied.

It would be appropriate for the DNIT to come out on top of this and issue ex officio a resolution clarifying the confusion that could be generated due to the referred suspension, even more so when this situation has been occurring since 2023, with the market operating as if the limitation of withholdings were not in force.

► Decree No. 3165/2024 - Whereby the real estate tax values are set for the taxable base of the real estate tax and its additions, corresponding to fiscal year 2025.

By means of Decree No. 3165/2024, the Executive Branch fixed the real estate tax values established by the General Directorate of the National Cadastre Service ("DGSNC") of the Ministry of Economy and Finance, which will serve as the taxable base for the determination of the real estate tax and its additions for the fiscal year 2025.

The adjustment made implies an increase of 3.6% in real estate values, both for urban and rural properties, based on the inter-annual variation of the CPI at the end of October 2024, as reported by the Central Bank of Paraguay.

It is important to remember that the amount of the tax is determined by applying the corresponding rates (normally 1%) on the fiscal valuation of the real estate established by the DGSNC (taxable base), which is made up as follows:

1. Urban real estate: land value (m² of the real estate per G/m²) plus built value (m² of the buildings per G/m²). The G/m² is determined by the type of pavement with the highest value of the adjoining streets (fronts) of the property for the land value, and by the construction category for the buildings.

2. Rural properties: Land value (hectare ("ha") of the property per G/ha). The tax valuation of each district is determined according to its opportunity cost (distances to urban centers and accessibility) and the predominant type of soil, according to the categories indicated in the decree.

It also provides, among other things: the valuation of properties that change from urban to rural category and vice versa, the procedure for the exemption of 50% of the tax for rural properties with forestry priority or with real right of forestry surface, and the discount for rural properties with low productive areas that differ from the type of soil of their district.

The amount of the tax to be paid to the municipality can be consulted through the DGSNC website, in the municipalities section, real estate tax liquidation section, subsequently selecting the department of residence, the district and the cadastral nomenclature of the property (padrón or current account).

JANUARY - 2025:

► Decree No. 3,237/2025 - Requirements for importers under the RTC are relaxed.

The RTC was established by Decree No. 2063/2024, providing for the intervention of 4 subjects, of which 2 would be taxpayers registered before the DNIT that would operate commercially under such regime. These taxpayers were classified, according to their function, as (1) traders and (2) importers ("RTC Importers"), the specific requirements for the latter being stricter, which were revised and made more flexible in Decree No. 3237/2025 ("RTC-2 Decree").

Originally, RTC Importers could not operate as such if they had not been in the commercial circuit for at least 2 years; however, Decree RTC-2 changed this, allowing companies with less than 2 years to operate by presenting a bank guarantee of USD 25,000 or its equivalent in guaranies, valid for at least one year from the date of the application, to cover their possible liability for tax or customs infractions.

Another change introduced by Decree RTC-2 with respect to the requirements for RTC Importers consists in the reduction of the minimum integrated capital required of them, since it was originally G. 6,000,000,000 and now it has been reduced to G. 300,000,000, but with limitations up to G. 3,000,000,000,000 of integrated capital. This is because the reduction of the minimum integrated capital was linked to the reduction of the minimum banking movement in the last quarter -which was originally USD 200,000-, and to the establishment of a limit of imports according to the integrated capital, as follows:

In addition to the above, Decree RTC-2 extended the validity of the habilitations under the previous tourism regime of Decree No. 1931/2019, which would now expire on a future date to be set by the DNIT, instead of as of the effectiveness of Decree No. 2063/2024 in July of that year, as originally foreseen.
 
Another innovation of Decree RTC-2 consists in providing that the DNIT will prepare a risk profile of the RTC taxpayer, including that of its related persons (representatives, main shareholders or partners), which will be taken into account during the processes of continuous monitoring of the importers' compliance with their obligations.
 
Finally, Decree RTC-2 provided that the DNIT will proceed to suspend the status of beneficiary of the RTC of those taxpayers with respect to which any of the following situations are detected during a control or verification process:

1. The beneficiary of the RTC or his legal representatives are not located at the domicile declared in the RTC registry.
2. The importer or his legal representatives do not attend the summons made by the DNIT without a duly justified cause.
3. The importer or its legal representatives ignore one or more requirements made by the DNIT.

The suspension to operate under the RTC will be lifted once the situation or situations that gave rise to this measure are remedied in the manner and conditions to be determined by the DNIT.
 
If you wish to learn more about the RTC and Decree No. 2063/2024 that established it, we invite you to read the article published about it on this website by clicking here .
 
► Decree No. 3.108/2019 - The percentage of guarantees to be submitted for the accelerated VAT refund regime is set for 2025 (UPDATE).
 
Article 102 of the Tax Law provided that exporters and freight forwarders may request the accelerated refund of the VAT credit affected to their export or export freight operations, presenting for this purpose a bank guarantee, financial guarantee or insurance policy with a minimum validity of 90 business days from the date on which the refund request is filed.
 
For the first 3 refund requests under the accelerated regime, the guarantee must cover 100% of the capital of the VAT credit required to the DNIT, plus accessories. From the fourth application onwards, the guarantee must only cover the portion of the VAT credit resulting from the average percentage of rejected credits ("PCR") under the accelerated regime in the months from January to November of the previous year, plus accessories.
 
To establish the value of the guarantee, the applicant must multiply the PCR by the VAT credit for which a refund is requested. The following legal accessories must be added to the resulting amount, calculated until the expiration date of the guarantee on the amount of the VAT credit resulting from the PCR: daily interest of 0.05% and late payment penalty of 12%.
 
The DNIT publishes the PCR annually, and on this occasion the PCR was set at 1.8% for 2025. This PCR represents a decrease of 168 basis points (-1.68%) with respect to 2024, which is practically a reduction by half of the 3.48% set for last year. This brings it back to levels similar to 2023, whose PCR was 1.75%. DNIT included the following example of a calculation for the guarantee with this publication:

A more direct way of expressing the total guarantee coverage as a percentage of the credit VAT is achieved by expressing the accessories as percentages of the PCR. This is achieved by estimating the interest at 6.7% (134 days times 0.05%) and the late payment penalty at 12%, which added together arrive at 19.7% of the PCR, which can be rounded up to 20%. To add this percentage directly to the PCR, it must be expressed as 1.20 times the PCR, which for a PCR of 1.8% means a total guarantee of 2.16% of the VAT credit.

In the cases in which the bank, financial or insurance policy guarantee is lower than the amount rejected, the taxpayer must immediately pay the difference in favor of the Treasury, plus the legal accessories that will be calculated until the total payment.

► Resolution No. 01/2024 - Legal entities that register as new taxpayers in the RUC must issue their vouchers only electronically.

By means of General Resolution DNIT N° 01/2024, it was provided that as from January 01, 2025, legal entities that register as new taxpayers in the RUC may only issue their vouchers electronically, through the E-Kuatia system or the E-Kuatia'i system, with the exception of the virtual withholding voucher.

In order to guarantee this measure, the resolution also establishes that, as of the aforementioned date, the DNIT will no longer issue stamps for means of generating vouchers other than electronic ones, with the exception of the aforementioned virtual withholding voucher.

This modified the provisions of General Resolution No. 105/2021, which had established January 1, 2024 as the starting date of the measure. The reason responded to the objective of achieving a sustainable and gradual implementation of the Integrated National Electronic Invoicing System ("SIFEN"), whose general regulations were updated in December 2023, by Decree No. 872/2023.

In this way, the generalized application of electronic invoicing is complied with 3 months after the mandatory calendar foreseen in Article 1 of General Resolution SET No. 105/2021, whose last date of application, foreseen for Group 10 in the mandatory scheme, was October 1, 2024. Thus, the new taxpayers affected by this measure become a sort of Group 11 of electronic invoicing.

FEBRUARY - 2025:

► Decree No. 3,339/2025 - The extension to the limit of changes in the lists of exceptions to the Mercosur CET is incorporated to the Paraguayan legal system.

The CET seeks to establish a uniform customs charge of all Mercosur member states towards goods from third countries within the framework of its regional integration process. However, due to the disparity of development among the different States parties and the need for economic competitiveness in the region, CMC Decision No. 58/10 foresaw that each State may establish a list of exceptions to the CET, within the following limits:

1. It cannot exceed a certain number of NCM codes, set for each particular State (Paraguay's limit is 649 NCM codes).
2. It cannot extend beyond a certain deadline, set differently for each State (Paraguay's deadline is December 31, 2030).
3. No more than 20% of the NCM codes included in the exception lists may be modified every 6 months (Paraguay's limit would be 129 NCM codes).

This last limit of modification to the number of NCM codes that may be modified as part of the lists of exceptions to the CET limits the capacity of Mercosur member states to adapt their customs policy instruments to their specific conjunctural needs. In view of this, CMC Decision No. 12/23 was issued, which authorizes the States Parties to suspend that limit until December 31, 2025, which was internalized by Paraguay through Decree No. 3,339/2025.

► Decree No. 3,379/2025 - Several amendments to the NCM and its corresponding CET are incorporated into the Paraguayan legal system.

The NCM is an instrument of economic and customs policy of the Mercosur member States that is constantly changing and adapting to the technical and economic needs of Mercosur as a bloc. In view of this, it undergoes constant changes and updates, some of which occurred in GMC Resolutions No. 05/23, 27/23, 28/23, 29/23, 30/23, 31/23 and 39/23, all of which were incorporated into the national legal system by Decree No. 3379/2025.

Details of the NCM codes modified by those resolutions can be found in the annex to Decree No. 3379/2025, which is available here.

Por medio de la Resolución C.A. N° 044-031-2025, de fecha 10 de julio de 2025 (la “Resolución”), el Consejo de Administración del Instituto de Previsión Social (IPS) aprobó un nuevo reglamento de infracciones administrativas, aplicable a todos los sujetos obligados al régimen del seguro social. La norma también establece un marco procedimental uniforme para la generación de planillas complementarias, ya sea por requerimiento judicial, solicitud del empleador o resultado de acciones de fiscalización institucional.

Entre los principales puntos se destacan:

• Actualización del sistema de días-multa: se mantiene el mecanismo previsto en la Ley N° 5655/2016, pero se eleva el valor de cada día-multa al 25% del jornal diario legal vigente, calculado sobre la base del salario mínimo dividido por 26. Este valor se ajustará automáticamente con cada modificación del salario mínimo legal.

• Multas agravadas por omisión de aportes: en los casos de omisión total o parcial de aportes obreros, especialmente cuando se trate de retenciones no ingresadas, se aplicará lo dispuesto en el artículo 68 del Decreto Ley N° 1860/50, aprobado por Ley N° 375/56 y modificado por Ley N° 98/92. La sanción será equivalente al doble del importe no ingresado, sin perjuicio de otras infracciones que pudieran corresponder.

• Bloqueo de certificaciones institucionales: el IPS no emitirá certificados de cumplimiento ni documentos similares a empleadores que cuenten con multas vencidas impagas o que se encuentren en proceso de sumario administrativo.

• Régimen de impugnación y efectos legales:
  • El pago de una multa o de los aportes en cuestión implicará la aceptación tácita de la resolución sancionatoria y la renuncia automática a iniciar o continuar solicitudes de reconsideración o sumarios administrativos.
  • El empleador podrá presentar una reconsideración ante la Dirección de Aporte Obrero Patronal (DAOP) dentro del plazo de 10 días hábiles desde la notificación o 30 días corridos desde el registro de la infracción en el sistema REI. Se requerirá documentación autenticada para sustentar la objeción.
  • En caso de rechazo, podrá promover un sumario administrativo ante el Consejo de Administración, el cual, si concluye desfavorablemente, conllevará la aplicación agravada de sanciones.

• Formalización de procedimientos y formularios: la Resolución aprueba 10 anexos normativos, los cuales reglamentan:
  • Planillas complementarias a pedido del empleador (Anexo 1),
  • Por orden judicial (Anexo 3),
  • Por acciones de control institucional (Anexos 4 y 5),
  • Procedimientos de impugnación (Anexos 6, 7 y 8),
  • Formularios normalizados (Anexos 2, 9 y 10), incluyendo un cuadro detallado para la determinación de multas.

• Destino de lo recaudado: el 100% de los ingresos por sanciones administrativas será asignado al Fondo de Administración General, conforme a lo previsto en la Ley N° 7446/2024.

• Derogación expresa del régimen anterior: se deja sin efecto la Resolución C.A. N° 019-017/2019, así como cualquier otra normativa de igual o inferior jerarquía que resulte incompatible con el nuevo reglamento.

Con esta medida, el IPS refuerza sus facultades de control y fiscalización, introduce mayor claridad procedimental y eleva los estándares de cumplimiento del régimen de seguridad social obligatorio, dentro de un marco más riguroso, automatizado y trazable.

Este contenido tiene únicamente fines informativos generales y no debe ser considerado como asesoría legal puntual. Si precisa asesoramiento específico no dude en contactarnos.

Presentamos un documento que consolida las tres entregas de nuestra serie sobre el sector energético en Paraguay. El material ofrece un análisis sobre la legislación vigente, licenciamiento, modelos contractuales, barreras normativas y oportunidades de inversión, con énfasis en energías renovables y desarrollo sostenible del sector.

Para obtener más información respecto de alguno de los temas abordados, por favor póngase en contacto con nuestros expertos: Manuel Acevedo (macevedo@vouga.com.py); Rodolfo Vouga Z. (rgvouga@vouga.com.py); Yvo Salum (ysalum@vouga.com.py)