Set up a company in Paraguay: when an EAS genuinely fits an international structure.
Paraguay combines a flexible company vehicle, a 10% headline business-income tax and practical local implementation. But a Paraguayan company is not a universal tax shortcut: income source, shareholder residence, effective management, dividends and real operations determine the result.
The EAS is flexible. International tax is less forgiving.
The EAS, created by Law 6480/2020, can be formed by one shareholder, accepts foreign shareholders and has no general minimum share capital. Formation runs through SUACE. International founders must coordinate shareholders, legal representation, RUC, income source and owner residence.
Typical route
Flexible, commercial, single-member capable and open to foreign shareholders.
When governance requires it
Investors, regulated activities or more complex governance may justify another form.
Strategy + execution
N30 Global tests the structure; N30 Paraguay handles local implementation.
“Paraguay company = 10% on everything.”
“Foreign customer automatically means foreign-source income.”
“Foreign owners never need local representation/RUC planning.”
“My home country ignores a Paraguayan company.”
IRE General/SIMPLE is 10%, but Law 6380 includes broader source rules.
Source depends on activities, assets, rights and specific statutory extensions.
SUACE and DNIT impose concrete legal-representative/RUC requirements.
Home-country company residence, CFC and transfer-pricing rules may still apply.
Foreign-owned EAS. Local representation still matters.
SUACE confirms that an EAS can have foreign shareholders and can be single-member. Where local documentation is insufficient to act directly, a duly appointed legal representative can be used. For RUC, DNIT General Resolution 34/25 requires a foreign legal representative to hold a valid Paraguayan civil ID.
EAS from one shareholder, individual or legal entity.
No general minimum or maximum EAS capital.
EAS incorporation through SUACE.
Foreign powers: apostille/legalisation and translation where required.
Principal legal representative needs local electronic identity/ID for SUACE.
RUC and later changes require current DNIT documents.
10% is the headline. Source and distributions decide the real outcome.
| Area | 2026 | Review |
|---|---|---|
| IRE | General and SIMPLE: 10% on taxable net income. | Source, regime and deductions. |
| Income source | Law 6380 starts with Paraguay-connected activities/assets/rights and adds specific foreign-linked rules. | Services, investment, financing and foreign tax. |
| IDU | 8% resident recipient / 15% non-resident under domestic law. | Ultimate owner, treaty and distributions. |
| VAT | 5% and 10%; 10% general rate. | Activity, exported services and invoicing. |
| RUC / Marangatu | Registration and recurring DNIT compliance. | Representative, activity, address and calendar. |
| Beneficial ownership | Corporate/UBO disclosures where applicable. | Owners, officers and changes. |
| Accounting | IRE, VAT, IDU, records, FS and e-invoicing may apply. | Regime, volume and invoicing. |
| Banking / KYC | Incorporation + RUC does not guarantee an account. | Business, UBO, residence and source of funds. |
Do not reduce Paraguay to “10% territorial”. Law 6380 contains specific source extensions.
Real business, investment, assets or presence in Paraguay.
Local vehicle needed to contract, invoice, hire or invest.
Personal residence and company management are coherent.
International planning plus local legal/accounting execution.
Living and managing everything abroad while seeking only a Paraguayan invoice.
Assuming every foreign-client receipt sits outside IRE.
Wanting no bookkeeping or recurring compliance.
Company with no commercial function beyond profit shifting.
Treaty protection helps. Substance still decides.
The Spain–Paraguay treaty entered into force on 14 October 2024 and generally applies to tax-year taxes from 1 January 2025. It covers IRE, IDU, IRP and INR and contains residence, PE, dividend and double-tax-relief rules.
The treaty expressly preserves CFC, thin-capitalisation and anti-abuse rules and includes a principal-purpose test. For dual-resident entities, place of effective management is decisive.
See Spain planningSee Paraguay tax residency
Strategy first. Local execution second.
Explore International Tax TailoringDefine the company purpose: operations, investment, holding, assets or hiring.
Compare EAS, SA or another form.
Map IRE, source, VAT, IDU and treaty.
Coordinate personal residence, effective management and CFC/PE risk.
Design RUC, representative, UBO, bookkeeping, invoicing and banking.
If Paraguay wins, N30 Paraguay executes locally.
Already know you need a Paraguayan company?
Move directly to local implementation with N30 Paraguay.
SEE N30 PARAGUAY COMPANY FORMATION →Questions to answer before incorporating.
Can a foreigner form an EAS?
Yes. Foreign shareholders are allowed and a qualifying legal representative can be used where required.
Can it have one shareholder?
Yes. Paraguay permits a single-member EAS.
Is there minimum capital?
There is no general minimum or maximum EAS capital, subject to special programmes/regulated activities.
What is the business tax rate?
IRE General/SIMPLE is 10% on taxable net income; VAT, IDU and other taxes may also apply.
Are dividends taxed?
Yes. Domestic IDU is 8% for residents and 15% for non-residents before treaty analysis.
Is Paraguay purely territorial for companies?
It uses source rules, but “local income only” is too simplistic because Law 6380 contains specific source extensions.
Do I need Paraguayan residence to own shares?
Not necessarily. Ownership and legal-representative/RUC requirements are separate.
Is there a Spain treaty?
Yes, in force since 14 October 2024 and generally effective for tax-year taxes from 1 January 2025.
Who handles local implementation?
N30 Global analyses; N30 Paraguay coordinates local execution.
Is banking guaranteed?
No. Approval depends on each bank and KYC profile.
Primary rules + real local execution.
First decide whether Paraguay belongs in your structure. Then make it operational.
N30 Global analyses the international structure. If Paraguay is the right answer, N30 Paraguay coordinates the EAS/SA, RUC, banking support and local compliance.