Tax in Paraguay

BKM | Berkemeyer

BKM | Berkemeyer‘s ‘outstanding‘ tax team is made up of experienced litigators who regularly represent clients in significant tax disputes before government entities, from municipalities to the Supreme Court. The group offers advice to foreign investors on Paraguay’s fiscal incentives schemes, and on import and export matters. The team assists clients with tax audits, and has extensive knowledge of tax regulations. Recent additions to its already extensive client base have included both local and international clients, such as AGT Networks and Delivery Hero. The team is co-led by Mauro Mascareño, who has experience in both local and international tax advice, as well as tax planning, tax litigation and tax refunds. Mascareño also leads the firm’s transfer pricing department. Co-head Federico Valinotti is a tax expert with extensive experience in the field, focusing on international investments and cross-border transactions. Carlos Vargas has extensive experience in local and international tax planning, litigation and credits. At the associate level, Rodrigo Gómez Sánchez advises public and private entities, corporations, guilds and non-profit entities, both local and foreign, on national and international tax law.

Practice head(s):

Mauro Mascareño; Federico Valinotti


‘BKM has a highly prepared work team, which has the necessary technological tools to perform in the best way. It has affordable and very competitive rates.

The outstanding team is made up of Mauro Mascareño, Carlos Vargas and Rodrigo Gómez Sánchez. The plus of this team is that they are very capable, efficient, provide alternative solutions and have a very good response time.

Key clients

Cámara Nacional de Comercio y Servicios del Paraguay.

Cámara Paraguaya de Farmacias (Cafapar)

Sacyr Concesiones

Rutas del Este

Perfecta Automotores

API Movilidad

SIF América

Exxis Paraguay

Scimitar Oryx Partners

Ubrique Desarrollos


Vía Brasil

Nativa Agrícola

Recsa (Amethyst)


American Tower Corporation (Blue Transfer)

Acciona Aguas

Tetra Pak

Amauri Getulio BIanchi

Incade – Universidad Americana

Agro Santa Fe

Consocio Energético Punta Cana Macao

FNV Capital

Agroganadera El Dorado


Codas Vuyk

Ñandutí Representaciones

Grupo Bazzi


Fortaleza SA de Inmuebles

Compañía de Petróleo y Asfalto (Compasa)

Addiuva Group

Fernando Talavera

Almacenes Generales Columbia

Astarte Capital Partners


Deriv Paraguay

Metro World Digital

Santex Group

Cargill Agropecuaria

South American River Company


Consorcio ASI Paraguay

Dlocal Paraguay

ECB Group

Fernando Leri Frizza

Johnson & Johnson del Paraguay

Cabral Comunicación Visual


Talavera & Ortellado Construcciones (Tocsa)

Unilever de Paraguay

Jeunesse Paraguay

Comercial Santo Tomás

AGT Networks


TCL Organic

Delivery Hero (Pedidos Ya)

Voith Hydro

Asociación Menonita de Ayuda Evangélica

Granos y Aceites

Telefónica Celular del Paraguay

Work highlights

  • Advised around 30 companies on filing an unconstitutionality class action against the last paragraph of section 15 of the tax reform act.
  • Assisted Raízen Paraguay with filing an action of unconstitutionality against certain rules regulating the international supply of fuel.
  • Advising Sacyr – Rutas del Este on day-to-day queries and consultations.


Ferrere has extensive experience in both tax and customs matters, advising on tax structures, transfer pricing reports and assisting international clients with operations in Paraguay. The group has expertise in tax litigation, handling cases from a variety of sectors, including digital services, hydrocarbon exploitation, special investment regimes, security markets, infrastructure and financial services. The firm has also been involved in the drafting of tax laws and regulations, actively assisting the Paraguayan Tax Administration, and in the implementation of free trade zones. Néstor Loizaga co-leads the team, offering advice on the tax aspects of investment regimes, M&A and corporate structures, and assistance with tax litigation. Practice co-head Erika Bañuelos is a senior associate with over 15 years’ experience advising national and international clients on tax and customs issues, including administrative processes, tax refunds, and proceedings against the tax authorities. Senior associate María Julia Méndez is an active member of the team, with experience in tax planning at both a national and multinational level. Tanya Moreno joined as senior associate in November 2022 from EY.

Practice head(s):

Erika Bañuelos; Néstor Loizaga


It is a very professional and focused team, showing solidity in the solutions. Undoubtedly, it is a firm with a prestige in the market that gives additional coverage to define analysis for decision making.

The team in general is empathetic and homogeneous in terms of cordiality and proficiency. Whenever necessary, we had responses on time and with the professional’s commitment, which adds value to the information and work.

Key clients



The Walt Disney Company


Bunge Paraguay



Impala Terminals

Marfrig Global Foods

Hidrovias Do Brazil

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

Navios Logistics




Asociación de Transitarios del Paraguay y Operadores Logísticos

Allied Tecnología

ThyssenKrupp Elevadores


Siemens Colombia

Regional Seguros



Grupo Bimbo


Megeve Investments

Roche Internacional

Terminal Occidental



Leoni Wiring Systems de Paraguay

Transbarge Navegacion

Work highlights

  • Advised Terminal Occidental on negotiating the contract with the government to operate the first free trade zone for services.
  • Advised Rabobank on the merger proposal between Sudameris and Banco Regional.
  • Advised Emergent Cold on the acquisition of a cold storage facility in Uruguay and Paraguay.

Mersán Abogados

Tax remains one of Mersán Abogados‘ main specialties, and the firm’s tax experts are regularly involved in the drafting of new regulations. The tax team offers advice on a full range of matters, including on the tax aspects of joint ventures, project finance and corporate structures. The practice is led by Diego Zavala Serrati and Tomás Mersan Riera. Pablo Cheng Lu is another key contact on the team. At the associate level, Federico Martinez is a name to note.

Practice head(s):

Tomas Mersán; Diego Zavala

Work highlights

Vouga Abogados

The team at Vouga Abogados advises both national and international clients on a range of complex tax matters. The firm offers advice on best tax practices and tax credit recovery processes, as well as advising clients on regulatory issues, including the recent tax reform bill and transfer pricing rules, introduced in January 2020 and 2021, respectively. The firm has also been involved in the double taxation treaties with Chile and Uruguay. The team is led by managing partner Rodolfo Vouga and 'excellent professional' Andrés Vera, who participated in the drafting of various tax regulations as part of his experience with the Finance Ministry. Along with associate Silvia Benítez, he leads the practice of tax recovery contentious matters before the administrative and civil courts. Associate Horacio Sánchez joined as a practice head from Ferrere in October 2022. He comes recommended as 'a great asset' and has extensive experience working with the tax authority and in applying tax treaties. Rodolfo Guillermo Vouga takes a lead role in some of the team’s key, multi-practice matters.

Practice head(s):

Rodolfo Vouga; Andres Vera


The team is very well prepared; they always answer our questions and respond quickly according to our requirements. Likewise, they are very well connected and have very good knowledge of the Paraguayan Stock Market, which is our business. They have lawyers who were part of the Paraguayan Stock Exchange and the National Securities Commission, which is a very important plus for us.

They provide personalised attention and responsiveness, as well as assisting us when we need them, whatever the day or time. Andrés Vera  assists us regarding legal and tax advice. He is an excellent professionals.

This year the firm has incorporated Horacio Sánchez to the team, and I think he is a great asset – not only for tax purposes but for other areas as well. As always, for labour and tax matters, it is undoubtedly the number one law firm in Paraguay, with unique teams of people with expertise, and a casuistry and practical experience that is unmatched by other law firms.

Andrés Vera and Horacio Sánchez stand out in the tax area. They have in-depth knowledge, command of the rules, vast experience, and I always feel calm when the answer comes from them.

We recommend Silvia Benitez.

Work highlights

  • Defending a client on charges arising from tax audits and tax assessments relating to transfer pricing issues.
  • Advising Paracel on all tax-related matters related to its $4bn cellulose plant in Paraguay.
  • Assisted a client with a two-step tax planning to eliminate the tax burden on dividends paid to foreign shareholders.

Estudio Nora Ruoti & Asociados

Tax boutique Estudio Nora Ruoti & Asociados advises its diverse client base on the full range of matters, including tax planning, tax audits, incentives, compliance and litigation. The team is led by Nora Ruoti, a renowned specialist in the field.

Work highlights

Olmedo Abogados

Olmedo Abogados‘ tax practice is supported by its accounting team. The practice assists with tax planning, tax regimes and tax regulations, as well as being well-versed in disputes with the tax administration at the administrative court. The team is co-led by José Ignacio Olmedo and Gustavo Olmedo. At the associate level, Carolina Lebrón is a name to note.

Practice head(s):

José Ignacio Olmedo; Gustavo Olmedo

Key clients

Total Tim

Plan Internacional

Work highlights

  • Assisted Total Tim with tax planning to help minimise tax implications and maximise investments, and providing annual advice to shareholder on applicable tax regimes.
  • Advising Amandau on daily issues regarding VAT and income tax.
  • Advising Plan International on a permanent basis on tax treatment and tax structure.

Peroni Sosa Tellechea Burt & Narvaja

Peroni Sosa Tellechea Burt & Narvaja regularly advises clients on tax structures for corporate transactions. The team has experience in international taxation, including transfer pricing, and has participated in tax controversies, handling double taxation queries, litigations and audits. The team is co-led by Juan Carlos Boggino, who has extensive experience in the practice area and focuses on custom controversies, tariff classifications and regulatory work. Senior associate Horacio Peroni co-leads the team and is praised by clients for his 'extraordinary' communication and services: he has experience in disputes and regulatory matters, and designs efficient fiscal structures for acquisitions.

Practice head(s):

Juan Carlos Boggino; Horacio Peroni


We deal with Horacio Peroni. We think he is an excellent professional, and the communication and services are extraordinary.

Good synergy between the head lawyers. Comprehensive attention to the client’s account and specialists in the tax area.

Personalized attention. In-depth understanding of the problem raised. Effective guidance and advice. Oriented to the result in favor of the client. Friendly treatment. The lawyers with whom I deal in the tax area Juan Carlos Boggino and Horacio Peroni.

Key clients

El Precursor

Guyracampana Agropecuaria y Forestal

Cervecería Paraguaya

CAA Guazú

Cofco International Services Paraguay

Cofco International Paraguay


Work highlights

  • Representing Cofco Group in 19 claims against the tax administration for the refund of tax credits.
  • Advised Cervecería Paraguaya on a claim before the national customs office that allowed it to obtain the 0% customs tariff for the importation of malt to Paraguay.
  • Advised El Precursor on the design of the most efficient tax structure for the sale of real estate assets.