Tax in Paraguay

BKM | Berkemeyer

As a leader in the sector, BKM | Berkemeyer’s ‘highly-trained’ tax team is involved in innovative projects, advising on the tax aspects of PPPs and industry installation. Working closely with the government, the practice is at the forefront of changing legislation in the sector, active in the drafting of regulations, as well as representing clients in constitutionality challenges. It regularly represents clients in tax litigation at all levels, including before the Supreme Court. As well as key industry players, the team also advises high-net-worth individuals and families on tax and estate planning. The firm boasts an established customs practice and a transfer pricing department. Federico Valinotti strengthens the team’s cross-border capabilities, with a wealth of experience in international investment and multi-jurisdictional transactions. Carlos Vargas focuses his practice on tax incentive regimes, advising a clientele of foreign investors on conducting business in Paraguay. Mauro Mascareño left the team in March 2024, along with associate Rodrigo Gómez Sánchez.

Responsables de la pratique:

Federico Valinotti


Les références

‘Berkemeyer’s tax team is extremely solid and multidisciplinary. The above translates into efficiencies when posing and solving challenges at the level of the companies they advise.

‘Efficiency, practicality, business knowledge. The final product is extremely remarkable.

‘Experience, knowledge and high quality of partners.’

Principaux clients

Cámara Nacional de Comercio y Servicios del Paraguay.


Raices Real Estate / Prosperar / Paraguay Sotheby’s International Realty


Sacyr Concesiones


Rutas del Este


Cámara de Comercio Paraguayo Mexicana – Capamex


Perfecta Automotores


API Movilidad


SIF América


Exxis Paraguay


Scimitar Oryx Partners


Ubrique Desarrollos


Casatúa


Vía Brasil


Nativa Agrícola


RECSA (Amethyst)


Universal


American Tower Corporation


Acciona Aguas


Amauri Getulio BIanchi


Patricia Marchewka


Agro Santa Fe


Consocio Energético Punta Cana Macao


FNV Capital


Agroganadera El Dorado


Produza


Codas Vuyk


Ñandutí Representaciones


Grupo Bazzi


Araguaney


Fortaleza SA de Inmuebles


Compañía de Petróleo y Asfalto (Compasa)


Addiuva Group


Fernando Talavera


Almacenes Generales Columbia


Astarte Capital Partners


Beiersdorf AG


Deriv Paraguay


Metro World Digital


Santex Group


Cargill Agropecuaria


South American River Company


Sodrugestvo


Consorcio ASI Paraguay


Dlocal Paraguay


ECB Group


Fernando Leri Frizza


Johnson & Johnson del Paraguay


Cabral Comunicación Visual


Tavamay


Talavera & Ortellado Construcciones (TOCSA)


Unilever de Paraguay


Jeunesse Paraguay


Comercial Santo Tomás


AGT Networks


Raízen


TCL Organic


Delivery Hero (Pedidos ya)


Voith Hydro


Asociación Menonita de Ayuda Evangélica


Granos y Aceites SACIA


Principaux dossiers


  • Advised around 30 companies in filing an unconstitutionality class action against the last paragraph of section 15 of the Tax Reform Act, which was declared admitted by the Supreme Court.
  • Advised Raízen Paraguay on the preparation and filing of an action of unconstitutionality against certain rules regulating the international supply of fuel.
  • Advising Sacyr – Rutas del Este on day-to-day tax queries and consultations.

Ferrere

Ferrere boasts a successful track record in defence against customs matters, with experience in matters related to customs duties, customs valuation and set prices for intra-group traded goods. It has a strong background in tax litigation, representing clients in contentious proceedings before the tax administration. The practice has been called upon by the administration to advise on legislation, thanks to its expertise in dividends and profits, special investment regimes and tax refunds. Néstor Loizaga leads the team, advising national and international clients on the tax aspects of investment regimes, M&A and corporate structures. Promoted to the partnership in August 2024, practice co-head Erika Bañuelos brings extensive expertise in international tax matters to the team, as well as experience in litigation, representing clients in administrative proceedings and before the tax authority. Senior associate María Julia Méndez spearheads the team’s customs work, leading successful inquiries against the customs authorities. Tanya Moreno, senior associate, focuses her practice on international tax matters and investment regimes.

Responsables de la pratique:

Erika Bañuelos; Néstor Loizaga


Les références

‘Tax team with a very high degree of technical knowledge of local and international taxes.’

‘A very high level of understanding of international financial solutions.’

Principaux clients

BASF


Netflix


The Walt Disney Company


Credicentro


Bunge Paraguay


Electropar


Cargill


Impala Terminals


Marfrig Global Foods


Hidrovias Do Brazil


Consorcio del Sur (Eurofinsa and Ingeniería de Topografía y Caminos)


Navios Logistics


Colprem


Richford


Agrofertil


Asociación de Transitarios del Paraguay y Operadores Logísticos


Allied Tecnología


ThyssenKrupp Elevadores


3M


Siemens


Regional Seguros


Vale


Interbarge


Grupo Bimbo


Silvicapital


Megeve Investments


Roche Internacional


Terminal Occidental


Elkem


Cummins


Leoni Wiring Systems de Paraguay


Transbarge Navegacion


Interfisa Banco


Corporación Andina de Fomento


JP Morgan Chase


Siena


Carbon Solutions Services


Kingspan Isoeste


Trafigura


Inpasa


Walden Capital Partners


ICON Wirtschaftstreuhand GmbH


Principaux dossiers


  • Assisted Interbarge in an administrative proceeding initiated due to a claim made by the Administración Nacional de Aduanas in connection with customs duties allegedly owed by the entity for the extension of the leasing contract entered with a non-resident lessor.
  • Advised Interfisa on the implications and tax risks that could arise from using the instant payment method.
  • Advising Andritz AG on the tax matters related to the operation of Paracel as well as its free trade zone user agreement with Paracel.

Vouga Abogados

Vouga Abogados remains ahead of the curve in terms of legislative changes, advising on tax credit recovery, transfer pricing matters and Paraguay’s double taxation treaties. With a growing list of national and international clients, the practice is called upon to advise on cross-border tax planning, the fiscal treatment of investment funds and customs matters. It is also well-equipped to represent clients before the tax and customs authorities. Practice co-head Andrés Vera boasts public-sector experience, participating in the drafting of tax-related legislation; he is regularly sought out by clients to advise on tax-efficient structures, thanks to his specialist knowledge of transfer pricing, VAT and tax credit recovery regulations. Bringing a wealth of international experience to the team, senior associate Horacio Sánchez co-heads the practice and is an expert in investment funds and the application of tax treaties. Rodolfo Guillermo Vouga is active in cross-border matters, specialising in foreign direct investment and fiscal incentives. Associate Silvia Benítez plays a key role in contentious tax recovery matters, with experience before both civil and administrative courts.

Responsables de la pratique:

Rodolfo Vouga; Andrés Vera; Horacio Sanchez


Les références

‘We work mainly with Andrés Vera in the tax area. Andrés has solid knowledge of the subject and a notable ability to quickly and efficiently absorb knowledge about the business, and transmit ideas and knowledge. These qualities differentiate him in the market, without a doubt.

‘The remarkable ability to quickly and efficiently absorb business knowledge, transmit ideas and knowledge.’

‘The team has excellent professional training and marked expertise.’

Principaux clients

Archer Daniels Midland (ADM Paraguay)


Naviera Chaco


AIC Seguros


Prosegur Paraguay


Consorcio Expo – UIP / ARP


UIP (Paraguayan Industrial Association)


British American Tobacco Productora de Cigarrillos – PROBAT


Copetrol


Paraguay Energy (Nextar)


John Deere Financial Chile – JDF


Zavidoro Corporations


GLT Casa de Bolsa


Grant Thornton


Paracel


SMS Argentina


Alcogreen


Aecom


Avalon Administradora de Fondos Patrimoniales de Inversión


Ecosecurities


Universidad Autónoma de Asunción


Principaux dossiers


  • Advised Paracel on the free trade zone regime for its operations to optimise its tax burden and assisted with the public offices that are involved in the establishment of the free trade zone.
  • Advised Ecosecurities on the fiscal impact of its projected operations in Paraguay.
  • Assisting Zavidoro with the preparation of its transfer pricing analysis for the fiscal years 2021, 2022 and 2023.

Mersán Abogados

With a strong track record in litigation against the tax authority, Mersán Abogados regularly participates in tax disputes. The team advises national, international and multinational companies on tax matters related to JVs, project financings and other transactions. Practice head Diego Zavala advises on tax aspects of M&A and assists clients in tax-related disputes. Tomás Mersán Riera brings extensive knowledge of tax regulations to the team, guiding clients through constitutional challenges before the Constitutional Chamber of the Supreme Court of Justice. At the associate level, Federico Martinez advises on the tax implications of contract negotiations and interactions with the tax authority.

Responsables de la pratique:

Tomás Mersán Riera


Les références

‘Quick and personalized response to queries. Good use of technological tools that helps optimise communication and provide better service. Independent management of the administration, regarding the provision of services.

‘The services provided by Estudio Mersán are characterised by being agile and of very good quality. In general, we receive answers to our queries in a very short period of time, and they are clear and concise.’

‘We highly value the clarity with which tax issues are analysed and the forcefulness of the opinions. We found in Tomás Mersán and Federico Martínez the support we expect to analyse the different tax situations that arise in the operations of our business. Expectations are more than met.’

Principaux dossiers


Peroni Sosa Tellechea Burt & Narvaja

Peroni Sosa Tellechea Burt & Narvaja‘s expertise in international tax matters sees it advise on transfer pricing and double taxation queries. It has a strong contentious practice, providing representation in tax controversies and audits initiated by the tax administration. The team is experienced in customs matters, and fields niche expertise in the refund of tax credits. Practice head Juan Carlos Boggino represents clients in tax audits and litigation, handling customs duty, double tax treaties, transfer pricing and VAT disputes. He leads the team alongside junior partner Horacio Peroni, who fields a strong international tax practice and advises on tax aspects of corporate and financial transactions.

Responsables de la pratique:

Juan Carlos Boggino; Horacio Peroni


Principaux clients

Alltech Paraguay


Agropecuaria Oro Verde


Inmobiliaria La Ponderosa


Alcoy


Felber Forestal


El Precursor


Guyracampana Agropecuaria y Forestal


Cervecería Paraguay


Caa Guazú


Cofco International Services Paraguay


Cofco International Paraguay


Vemarcorp


Principaux dossiers


  • Representing FLS Group in a $200m project to convert 68,000 hectares of degraded grassland into 50,000 hectares of sustainably managed commercial plantations and 18,000 hectares of reforested mosaic-planted nature conservation areas.
  • Assisting Green Pastures Group in obtaining a $5m loan from a foreign bank for the acquisition of a new real estate property.
  • Representing Cofco International Services Paraguay and Cofco International Paraguay in claims before the Tax Administration for the refund of tax credits, for approx. $1,960,000.

Olmedo Abogados

The tax team at Olmedo Abogados works in tandem with the firm’s accounting department to advise clients on key legislative and regulatory changes in the sector. Practice co-head Gustavo Olmedo specialises in tax law, including litigation. He leads the team alongside José Ignacio Olmedo, who excels in the drafting of profit allocation mechanisms. Jose Vargas Peña is an active member of the group, alongside fellow senior associate Carolina Lebrón, who brings both public and private-sector experience to the team.

Responsables de la pratique:

Jose Ignacio Olmedo; Gustavo Olmedo; Carolina Lebrón; Jose Pedro Vargas Peña


Principaux clients

Total Tim


Simbiose


Woden Paraguay


Msk


Isagro Argentina


Principaux dossiers


  • Advising Total Tim Paraguay on the best profit allocation mechanisms to reduce tax on revenue and on the avoidance of contingencies related to the distribution or non-distribution of profits.
  • Advising Woden Paraguay on best practices to comply with tax regulations and assisting the client on tax efficient compensation schemes for its senior management.
  • Advised MSK on the settling of cross border debts with its related companies, and the most efficient mechanisms to do so from a taxation point of view.