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Paraguay Provides Guidance on Application of Transfer Pricing Rules

05 October 2021

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Approved Changes

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Paraguay

Paraguay's tax authority (SET) has announced the issuance of General Resolution No. 96 of 15 September 2021, providing guidance on the application of the transfer pricing rules introduced by Law No. 6380/2019 and regulated by Decree No. 4644/2020. Key aspects of the resolution include: Clarification that the transfer pricing rules apply for operations with related parties resident in Paraguay, including parties in a free zone or a maquiladora company, if the operation is exempt from or otherwise not subject to corporate income tax (IRE) for one of the related parties; Guidance on when parties of an operation are considered related,...