The tax administration of Paraguay regulated the Transfer Pricing Technical Study (ETPT) and clarified aspects related to its content, forms, terms and conditions for its presentation. For this purpose, the Undersecretariat of State for Taxation (SET) issued General Resolution No. 115/2022.
They are reached: (a) taxpayers of the Corporate Income Tax (IRE) that enter into transactions with parties related to residents abroad or in the country when the transaction for one of the parties is exempted, exempt or not subject to IRE, and whose gross income in the immediately preceding fiscal year exceeded G. 10,000,000,000 (guaraníes ten billion), equivalent to approximately USD 1.4 million (at the exchange rate of July 2022); and/or (b) IRE taxpayers that carry out transactions with residents of countries or jurisdictions with low or no taxation, including users of free trade zones or maquiladora companies, provided that the linkage has not been distorted.
Exceptionally, it was provided that taxpayers with fiscal year-end as of 04/30/2021, 06/30/2021 and 12/31/2021, may comply with the obligation related to the technical study and its presentation until 10/31/2022 without incurring in a violation for contravention.
It is important to mention that the ETPT must be ratified by the Authorized Transfer Pricing Professional registered in the Registry (PAPT) through the “Marangatu” System using its own confidential user password.
Those taxpayers with fiscal year-end as of 04/30/2022, 06/30/2022 and 12/31/2022 may file the ETPT corresponding to fiscal year 2022, within the ordinary deadlines established in Art. 9 of the General Resolution.
Click here to download the document with the details of the above mentioned regulations.a.
