New Filing Tools for the Technical Transfer Pricing Study 

July 24, 2023

The Undersecretariat of State for Taxation of Paraguay (SET) published General Resolution N°134, which exceptionally establishes the filing tools for the Technical Transfer Pricing Study and other supporting documents for the devaluation of the presumptive connection with foreign residents. 

1. Background

Resolution No. 134 repeals Article 5 of General Resolution No. 127/2023, which established administrative measures related to the Informative Affidavit for exports of goods affected by number 7 of Article 38 of Law No. 6380/2019. Likewise, it clarifies matters regarding the devaluation of the alleged connection foreseen in the penultimate paragraph of the tax law. 

2. TTPS content

The due date for the TTPS filing corresponding to fiscal years 2022 and 2023 of those taxpayers with fiscal years ending on December 31, 2022, and April 30, 2023, will be regulated by the provisions of Article 9 of General Resolution No. 115/2022.  

Exceptionally, it may be digitally filed through the SET’s entry desk in a storage medium such as CD, DVD, or USB memory, as referred to in Article 7 of General Resolution No. 115/2022. On the other hand, each Study must be duly validated with the signature of the authorized professional until the option of ratification by a professional is available in the Marangatu system. 

3. Supporting Documentation Content

Regarding the supporting documentation that devaluates the alleged connection with residents abroad, corresponding to the transactions carried out in fiscal years 2022 and 2023 by those taxpayers whose fiscal year end is December 31, 2022, April 30, 2023, and June 30, 2023, these must be filed at the SET’s entry desk in portable format. 

4. TIN Registration

On the other hand, the SET issued General Resolution N°133, which amends articles regulating TIN registration. In this regard, foreign individuals with temporary or permanent residence will have the TIN identifier according to the ID card number. 

Source: ABC Paraguay 24/07/23