Comparative study of the transfer price regime in Paraguay

Abstract

The implementation of the Transfer Pricing Tax Regime in Latin America and the Caribbean is located mainly in the last decade of the 20th century, in 2021 the CIAT (Inter-American Center of Tax Administrations) carried out a study called Database on Standards and Practices transfer pricing in Latin America and the Caribbean, where the growing evolution of the incorporation of Paraguay’s PT regulations can be noted through a comparative study of the PT Regime with Argentina, Ecuador, Panama, Venezuela and Colombia by 2021. Regarding the criteria used, Para- guay has taken the criteria of the OECD and of the country itself, meanwhile others used their own tax criteria, or a combination of both. Another aspect to highlight is that neighboring countries such as Argentina and Venezuela included the PT regime in their tax regulations in 1998 and 1999 respectively, on the other hand, using only OECD Criteria Colombia, Ecuador and Panama did so in 2004, 2005 and 2011, on the other hand, Paraguay in 2019 introduced TP regulations through Law 6380/2019 on the Modernization and Simplification of the National Tax System, and put into effect in 2020, thus positioning Paraguay as the last in the Database. of the IATTC.