Paraguay Transfer Pricing Documentation Requirements
Paraguay requires a transfer pricing technical study and an accompanying return from taxpayers whose gross income exceeds the threshold, filed through the tax authority's electronic platform. Single-year testing is mandatory, and penalties apply to inaccurate or late filings.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Technical study
Required | Gross income exceeding the statutory threshold | 7th month after fiscal year-end | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | ES | Yes (maximum formal-noncompliance penalty in force) |
TP return With technical study
Annual filing | Taxpayers within the transfer pricing rules | 7th month after fiscal year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes |
Calculate your exact Paraguay deadline
Enter your entity’s fiscal year-end to return your exact Paraguay preparation or filing date. Available without registration.
Scope of the documentation obligation
A taxpayer whose gross income, that is, sales, exceeds the statutory threshold must prepare transfer pricing documentation in the form of a technical study, filed together with a transfer pricing return through the tax authority’s electronic platform via the taxpayer’s user profile. Both are due in the seventh month after the fiscal year-end, with the exact date depending on the taxpayer’s identification number. There is no Country-by-Country reporting obligation in the regime as captured.
Distinctive features of the Paraguayan regime
Two features distinguish the Paraguayan regime. The first is the mandatory single-year analysis: testing must use the year under analysis, and multi-year information for an uncontrolled operation is justified only where needed to analyse business cycles or where the sector was affected by atypical circumstances in the year, which is stricter than the multi-year norm common across the region. The second is the integrated electronic filing of the technical study with the return, so the substantive study reaches the authority as part of the routine compliance cycle. Penalties attach to presenting a study with inaccurate data, filing out of time, or failing to keep the supporting documents during the limitation period, set at the maximum penalty for formal non-compliance in force at the time.
Benchmarking and comparables
Both local and foreign comparables are allowed, and recent rules direct the rejection of comparables with operating losses in defined circumstances. Single-year testing of the year under analysis is mandatory. A roll-forward of the comparable companies with a financial update using information of the year under analysis is preferred. The general limitation period for tax matters is five years.
Frequently asked questions
Does Paraguay require single-year or multi-year analysis?
Single-year testing of the year under analysis is mandatory. Multi-year information for an uncontrolled operation is justified only where needed to analyse business cycles or where the sector faced atypical circumstances in the year.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.