Novedades Tributarias – agosto 2026

► Decree No. 6484/2026 – New amendments to the MERCOSUR Common Nomenclature and Common External Tariff are incorporated into domestic law.

Through Decree No. 6484 of 3 August 2026, the Executive Branch incorporated into domestic law MERCOSUR Common Market Group ("GMC") Resolutions Nos. 09/25, 17/25, 18/25 and 19/25, all entitled "Amendment to the MERCOSUR Common Nomenclature and its corresponding Common External Tariff". This partially amended the Annex to Decree No. 6897/2022, which consolidates the NCM and Common External Tariff (CET) in force in Paraguay. Under Article 7, the decree entered into force upon publication.

The amendments are technical tariff changes consisting primarily of new subdivisions (specific NCM codes) and adjustments to tariff heading descriptions. Notable changes include new subdivisions with a 0% CET for preparations containing vitamin B12 intended for animal feed, aluminium containers (capsules) for packaging coffee and similar products of the types used in beverage preparation machines, and apparatus intended for robot-assisted surgical procedures.

Specific subdivisions are also created to identify certain substances controlled under the Rotterdam Convention, pursuant to the World Customs Organization recommendation of 26 June 2025 (perfluorooctanoic acids and their salts, and terbufos); and new subdivisions, all with a 0% CET, are introduced for iron ore in briquettes of between 4 and 60 cm³, dabrafenib mesylate (which joins the list of oncology and antiretroviral medicines subject to a zero tariff), and safety headgear of the types used by firefighters, with an integrated visor and face shield (other safety headgear remains subject to a 20% CET). Adjustments are also made to subdivisions for certain polymers (HPEG), fabrics used as backing for the manufacture of sandpaper, steel tubes, copper powders, antennas for cellular telephone base stations and machinery parts.

At MERCOSUR level, GMC Resolution No. 09/25 provided for entry into force on 1 October 2025 (01/X/2025), while GMC Resolutions Nos. 17/25, 18/25 and 19/25 provided for entry into force on 1 February 2026 (01/II/2026), requiring the States Parties to incorporate them into their domestic legal systems before those dates. In Paraguay, however, the amendments apply from publication of Decree No. 6484/2026. Importers should review the correct tariff classification of their products in light of these amendments.

► Binding Ruling No. 898 – Zero-value (0) electronic invoices may not be issued to document the delivery of goods already paid for through advance payments.

Una contribuyente de la categoría de Grandes Contribuyentes consultó a la DNIT A taxpayer classified as a Large Taxpayer asked the DNIT whether its operating procedure was permissible. Under that procedure, it issues an electronic invoice for advance payments on account of products (recognising the VAT output tax at that time) and, upon partial or full delivery of the goods, issues a second "settlement" invoice linked to the advance-payment invoice, with a "total amount payable" of zero, for inventory control and documentary support purposes.

The DNIT stated that this practice is not permissible. Under Article 6(3) of Decree No. 872/2023, transactions involving advance payments require an electronic invoice for the amount received and, once the price has been finalised, a final settlement and an electronic invoice solely for any difference, linked to the advance-payment invoice. A zero-value document does not substantiate any valid commercial, tax or financial transaction.

As regards the movement of goods, the DNIT indicated that the appropriate way to document partial deliveries is to link one or more Electronic Delivery Notes to the invoice documenting the advance payment or, where applicable, to register the "transport event" provided for in Article 32 of Decree No. 872/2023 to amend or supplement the information relating to the movement of the goods.

► Binding Ruling No. 893 – Tax treatment of the repayment of funds contributed to a political organisation.

An individual requested a ruling on the tax treatment applicable to the recovery of personal funds previously advanced to a political organisation, the repayment of which had subsequently been approved by the competent bodies of that organisation.

The DNIT concluded that repayment of the contributed capital falls outside the scope of VAT, as there is no supply of goods or services, and therefore generates neither output tax for the applicant nor input tax credit for the political organisation. For personal income tax (IRP) purposes, the repayment likewise does not constitute taxable income, provided the contributions originated from income duly declared for that tax; conversely, if the contribution was previously deducted, its repayment will constitute taxable income. Any additional amount received, such as interest, will be subject to VAT and IRP. Finally, the transaction must be documented by the corresponding invoice pursuant to Article 92 of Law No. 6380/2019.

► Binding Ruling No. 890 – Gnocchi do not qualify as "noodles" within the basic food basket and are subject to VAT at 10%.

A pasta manufacturer asked whether its precooked and pasteurised noodles, as well as gnocchi, could be subject to the reduced VAT rate of 5% applicable to "noodles" within the basic food basket (Article 90(c) of Law No. 6380/2019 and Article 23(2) of Decree No. 3107/2019, which covers "uncooked noodles, fresh or dried, of any type").

As regards gnocchi, the DNIT concluded that the reduced rate does not apply and that the standard rate of 10% must be charged. It held that reduced rates constitute a tax benefit subject to strict interpretation, which cannot be extended by analogy; that gnocchi are made primarily from potatoes, with a production process and composition substantially different from those of noodles; and that they are not identified as noodles in ordinary or commercial usage. This ruling confirms the Tax Administration’s restrictive approach to defining the products within the basic food basket eligible for the 5% rate.

► The BCP and FLAR presented the study "Characterisation of Direct Investment (DI) in Paraguay" for 2008–2024: foreign investment increased steadily and diversified across sectors and countries of origin.

El 6 de agosto de 2026, el Banco Central del Paraguay y el Fondo Latinoamericano de Reservas presentaron el estudio On 6 August 2026, the Central Bank of Paraguay and the Latin American Reserve Fund presented the study "Characterisation of Direct Investment (DI) in Paraguay: a sectoral analysis for 2008–2024", prepared using firm-level information compiled by the BCP. The study concludes that DI was a sustained source of external financing for Paraguay, with average annual net flows of USD 590 million (1.6% of GDP) over the period analysed.

Foreign investment did indeed increase over the period studied. Average annual gross inflows rose from USD 1,566 million in 2008–2011 to USD 2,369 million in 2012–2015, USD 2,555 million in 2016–2019 and USD 2,994 million in 2020–2024. The last of these was the most dynamic subperiod, driven by trade, financial intermediation, the production of oils and transport. In 2024, net flows totalled USD 931 million (2.1% of GDP), one of the highest levels in the series. Capital contributions to DI enterprises rose from USD 244 million in 2008 to USD 561 million in 2024, while reinvested earnings increased from USD 211 million to USD 429 million. "Greenfield" investment (the creation of new projects and assets) predominated in 13 of the 17 years, although "brownfield" investment (the acquisition or expansion of existing businesses) reached a record USD 574 million in 2024.

By sector, non-financial services were the largest recipient, accounting for 44% of cumulative net flows over the period (approximately USD 4,400 million), led by wholesale trade, real estate activities, telecommunications, vehicle sales and inland waterway transport. Manufacturing followed with 26% (approximately USD 2,640 million), notably meat processing, the production of oils and fats, metal products, pharmaceuticals, beverages, automotive parts and fertilisers. Several of these activities benefited from incentive regimes such as maquila; the number of manufacturing enterprises with DI increased from 74 in 2008 to 334 in 2024. Financial services attracted 20% (approximately USD 1,960 million, concentrated in banks, finance companies and insurers) and were the most profitable sector according to the report, with an average return of around 20%. The primary sector had the smallest share (10%, approximately USD 1,000 million), although forestry and livestock farming have expanded recently.

As regards the origin of investment, the study identifies growing diversification: the number of investor countries increased from 39 in 2008 to 68 in 2024. In 2008–2015, the leading sources of investment were Brazil (17.3%), the United States (11.6%), Spain (11.4%), Argentina (6.4%) and the Netherlands (5.4%). In 2016–2024, Brazil (21%), the United States (12.5%), the Cayman Islands (8.5%) and the Netherlands (6.5%) consolidated their positions as key players, while regional partners gained prominence: Uruguay (5.9%), Argentina (5.8%), Chile (5.8%) and Colombia (3.9%).

The study concludes that, although Paraguay has made significant progress in creating an environment conducive to attracting investment through institutional and regulatory reforms, challenges remain in regulatory predictability, institutional efficiency, infrastructure and production linkages. It therefore recommends continuing policies aimed at diversifying the production structure and promoting higher value-added activities.

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