On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia or ETPT) and supporting working papers used in performing the analysis.

Previously, under General Resolution No. 115/2022 the ETPT be submitted in PDF format, while the supporting working papers must be presented in spreadsheet format (xls, xlsx, or odt), exclusively through the Marangatu System. However, an exception was made for fiscal years ending on April 30 and June 30, 2022, allowing companies to submit their ETPT and working papers using external storage mediums such as CDs, DVDs, or USB memory.

The latest development in General Resolution No. 134/2023 extends this requirement. It now permits the transfer pricing study (ETPT) and working papers to be exceptionally submitted in the required format using external storage mediums for fiscal years ending on December 31, 2022, April 30, 2023, and June 30, 2023. Additionally, the resolution allows documentation demonstrating that a non-resident entity is not related to a taxpayer to be submitted in PDF format using an external storage medium for fiscal years ending on the same dates.

Proving that a non-resident is not related is relevant for the requirement to submit the transfer pricing study (ETPT) for operations with non-residents in countries or jurisdictions with low or no taxation or with users of free zones or maquiladora companies. The exceptional mechanism to submit transfer pricing documentation using an external storage system is provided to permit more time for the SET to make the applications available in the Marangatu System and for taxpayers to adapt their computer systems.

This move by Paraguay’s tax authority aims to streamline the transfer pricing documentation submission process while ensuring that businesses have the resources and time needed to transition smoothly to the digital platform. Taxpayers are encouraged to stay informed about these changes and make the necessary adjustments to remain compliant with the new regulations.