On 16 April 2021, the tax authority of Paraguay has published General Resolution No. 86 with effect from 17 April 2021, regarding the application of the special transfer pricing (TP) rules, related to the sixth method, for certain commodity transactions, i.e. rice, soy products, corn, wheat, etc.
As per Decree No. 4644 of 30 December 2020 prices recorded for goods transactions must be adjusted in line with the destination prices established by markets or exchanges. The Resolution No. 86 provides that reference should be made to Listings on the Buenos Aires Cereal (Grain) Exchange; and Quotations published by the Economic Research Center of the Faculty of Agriculture “Luiz de Queiroz” of the University of Sao Paulo, Brazil (CEPEA).
If reference prices are not available from the above mentioned sources for the destination, destination market prices from other public sources information may be used. The resolution also clarifies rules regarding adjustments to the reference price regarding the requirements to register sales contracts for commodities, insurance and freight, and other related issues.
