The resolution establishes new rules for performing a transfer pricing analysis and clarifies “related parties.”The Paraguayan Tax Authority (Subsecretaría de Estado de Tributación) issued General Resolution No. 96/2021, which establishes new rules for applying the transfer pricing methods in Paraguay, among other things.BackgroundLaw No. 6380, enacted in 2019, established transfer pricing rules as part of a major tax reform in Paraguay. The rules went into effect 1 January 2021. The rules included provisions on the arm’s-length principle for transactions between related parties, and thus preventing tax base erosions.Decree No. 4644/20, issued 30 December 2020, regulated the transfer pricing regime. The...