Open a business in Paraguay. 10% corporate. 0% on foreign income. 72-hour incorporation.

From the law itself

What Ley 6380/2019 actually says.

The 10% headline is Article 21 of the 2019 tax-modernisation law, verbatim:

La tasa del IRE será del 10% (diez por ciento), sobre la renta neta.

The IRE rate shall be 10% (ten percent), on net income.

Why Paraguay for entrepreneurs

Why do foreign founders actually incorporate in Paraguay?

Headline rate, electricity cost, residency route and incorporation speed — Paraguay is the only LATAM jurisdiction in 2026 that stacks all four.

1. 01

   Territorial tax + 10% headline

   IRE (Renta Empresarial) is a flat 10% on Paraguay-source net income, with no progressive brackets — the same rate that applies to a one-person consultancy and a thousand-employee factory. Foreign-source income (a US software contract, a German distributor, a Brazilian client billed from your foreign parent) is outside the IRE base entirely. Compare neighbours: Brazil ~34%, Argentina 25–35%, Chile 27%, Uruguay 25%. *(Ley 6380/2019, Art. 21.)*

2. 02

   Electricity at LATAM-low rates

   Itaipú (14,000 MW) and Yacyretá generate vastly more hydroelectricity than Paraguay consumes domestically; the country exports surplus to Brazil and Argentina. The December 2025 X8 Cloud announcement (US$ 10–50 bn over 30 years, 4,000+ NVIDIA H100 GPUs in phase 1) and HIVE Digital's January 2026 acquisition of Bitfarms' 200 MW Yguazú site for US$ 56 M were both written explicitly on that cost basis. ANDE industrial tariffs sit near the bottom of the regional table.

3. 03

   Investor Pass — permanent residency in 5 days

   Resolución MIC Nº 0283/2026 (signed 21 April 2026) created the Constancia de Inversionista Extranjero — an administrative instrument that grants direct permanent residency, bypassing the temporary stage. Four tracks: productive investment from US$ 70,000 with five formal jobs, tourism US$ 150,000, real estate US$ 200,000, financial instruments US$ 200,000. CIE target is 5 business days; the DNM permanent-residency card follows in 3–6 months.

4. 04

   EAS — incorporated in roughly 72 hours

   Ley 6480/2020 created the *Empresa por Acciones Simplificadas* to replace SRL/SA friction for new founders. One shareholder allowed (natural person or legal entity), no minimum capital, fully digital through eas.mic.gov.py. Standard SUACE-routed timeline in 2026 is 5–10 business days end-to-end including RUC issuance — well inside what most countries call "month one".

These four levers don't have to be used together. Many foreign founders incorporate the EAS without going for residency at all (running the Paraguay company at arm's length from abroad). Others get the Investor Pass on a real-estate or financial-instruments track and never operate a company. The site treats them as separate decisions.

Three legal structures

EAS, SRL or SA — which Paraguayan structure should a foreign founder pick in 2026?

Three operating-company forms exist under Paraguayan commercial law. For new foreign founders the EAS is the right answer in almost every case; SRL and SA still serve specific needs.

• EAS — Empresa por Acciones Simplificadas

  Recommended. Single shareholder allowed (you alone are fine). No minimum capital. Standard bylaws designed for fast filing. Fully digital incorporation through the eas.mic.gov.py portal. Ley 6480/2020. *Cost reference:* DIY portal US$ 50–150; with a lawyer drafting custom bylaws around US$ 800–1,500.

• SRL — Sociedad de Responsabilidad Limitada

  Two-shareholder minimum. No statutory capital floor but ~PYG 5 million is the practical baseline. Cuotas (shares) rather than acciones; less liquid. Still useful where banks or clients specifically expect an SRL counterparty. Setup 2–4 weeks, US$ 3,000–5,000 with counsel.

• SA — Sociedad Anónima

  Two-shareholder minimum, formal board and síndico (statutory auditor) required. Higher administrative overhead. Worth the cost for capital-intensive projects, future external investors, or regulated activities (insurance, large-scale manufacturing). Setup 4–6 weeks, US$ 8,000–15,000.

• Branch (Sucursal)

  Registers a foreign parent as a Paraguay-resident branch rather than a separate entity. Useful when the foreign parent already has brand equity or contracts that need legal continuity. Requires apostilled parent documents, capital assignation, and roughly 4–8 weeks.

Foreign ownership in any of these structures is 100% allowed in nearly all sectors. The narrow exceptions — rural land within 50 km of a border for citizens of neighbouring countries, broadcast media concessions, certain river-fishing concessions — are sector-specific and don't apply to most operating companies. *See Sectors for the full list.*

Tax regimes worth knowing

General, Maquila or Free Trade Zone — which Paraguayan tax regime fits which model?

Most foreign founders use the general 10%/0% regime above. Two preferential regimes exist for narrower models:

• General regime — 10% IRE

  Default. Pays IRE 10% on Paraguay-source profit, IVA 10% on domestic sales, IDU 8% (resident) or 15% (non-resident) on distributed dividends. Foreign-source revenue is exempt at company level. This is where the consulting firms, SaaS holding companies, e-commerce operations, marketing agencies, real-estate brokers, and family businesses live.

• Maquila — 1% tributo único

  Ley 1064/97, modernised in September 2025 to include service maquilas. A 1% single tax on the greater of (a) value added in Paraguay or (b) monthly export value, replacing IRE, IDU and most other levies. Designed for export-oriented manufacturing and (since 2025) services — textiles, autoparts, electronics assembly, pharma, BPO, software-as-a-service exported to a foreign parent. Requires CNIME approval and a maquila contract with a foreign principal.

• Free Trade Zone — 0.5% on third-country exports

  Ley 523/95. Companies operating inside a Zona Franca (Ciudad del Este or Villeta) pay 0.5% on gross revenue from exports to third countries, plus 0% IVA and 0% import duty on operational inputs. Goods or services sold into the Paraguay domestic market revert to the regular regime. Best for warehousing/distribution hubs and large industrial projects. *See the full Free Trade Zones guide for the legal substitution rules.*

• Investment incentives — Ley 7548/2025

  Signed by President Peña on 9 September 2025, replacing the 35-year-old Ley 60/90 framework. Customs and IVA exemptions on imported capital goods, and an extended dividend exemption for both domestic and foreign investors in qualifying projects. Maximum benefit period now capped at 20 years. By end-2025 around 140 projects worth roughly US$ 700 M had been approved under the transition. Filed at MIC + Hacienda with a project plan.

These are stacked, not mutually exclusive. A maquila with an FTZ presence is unusual but legal; a general-regime operating company can hold Ley 7548 status for capital-equipment imports. A Paraguay accountant should pick the combination — the model only works if substance is real (employees, lease, utilities), not paper-only.

Where the FDI is going in 2026

Which Paraguayan sectors did foreign capital actually back in 2025–2026?

Investment Grade ratings from Moody's and S&P landed in July 2024. By Q1 2026, DNM had logged a record 18,071 residency applications (+85% YoY) and the State Department's *Investment Climate Statement 2025* singled out Paraguay's macro stability among LATAM. The 2025-2026 deal flow tells the same story:

• AI data centres & sovereign cloud

  The headline 2026 story. X8 Cloud (announced Dec 2025) — phased US$ 10–50 bn over 30 years, first phase US$ 250 M and 6 MW with 4,000+ NVIDIA H100 GPUs, scaling to 250 MW and 165,000+ GPUs. HIVE Digital acquired Bitfarms' 200 MW Yguazú hydro-powered site in January 2026 for US$ 56 M and is bringing total in-country capacity to 400 MW by Q3 2026. The IDB signed a US$ 130 M facility for sovereign cloud + Tier-III government data centre. In March 2026 the MIC Minister led a Silicon Valley delegation pitching Paraguay directly to OpenAI, NVIDIA, Crusoe and Lambda.

• Agribusiness & beef exports

  Agriculture is ~20% of GDP and ~75% of exports. USDA FAS projects MY2025/26 soybean production at 10.9 MMT and exports at 7.2 MMT. Beef exports forecast around 450,000 t CWE for 2025; Paraguay sits inside the global top 10. Pasture economics are favourable, capital costs low, and EU and Asian beef-import quotas are increasingly open.

• Forestry, carbon & agroforestry

  World Bank approved US$ 100 M on 30 April 2026 to scale sustainable agroforestry through Paraguay's national development bank — FSC certification a baseline. Paraguay Carbon Forum 2026 (March, Asunción) profiled jurisdictional REDD+ projects and the Paraguay–Singapore Article 6 bilateral. Carbon Pulse estimates sector revenue potential above US$ 100 M/year if the compliance market matures.

• Real estate & land

  Foreigners may own urban land outright, no residency required. The only restriction is rural land within 50 km of an international border, and only for nationals of bordering countries (Brazil, Argentina, Bolivia) — non-bordering foreigners (US, EU, UK, Asian) are not blocked, although a procedural Defence + Interior permit may apply. Asunción condo prices remain a multiple cheaper than São Paulo or Santiago. Our advisory partner [homesparaguay.com](https://homesparaguay.com/) handles concierge land + property purchases.

• Crypto mining

  Legal and regulated, not a Wild West. ~45 licensed operations + ~20 pending. MIC issues the operating licence, ANDE the industrial electricity contract, DNIT the tax registration, SEPRELAD oversees AML. Bitcoin mining sits on the same cheap-hydropower thesis as the AI data centres. *Full breakdown in the Crypto guide.*

• Medical cannabis

  Ley 6007/2017 created the PROINCUMEC framework under DNVS (Ministry of Health). Originally five licences; expanded to twelve; no statutory cap. Export-oriented medical products are the predominant model. Compliance burden is real — pharmaceutical-grade facilities, DNVS audits — but the regulatory door is open.

These are the headline 2026 stories. Smaller foreign-founded businesses in software exports, professional services, hospitality, and import-export trade are the steady backbone of the existing EAS register and don't require sector-level incentives to work.

How it actually goes

How long does it take to go from decision to an operating Paraguayan company?

Realistic 2026 timeline assuming an EAS with one foreign shareholder, no prior visit required:

1. 01

   Decide the structure (day 0)

   EAS in almost every case. Pick a Paraguayan accountant. Reserve a company name via SUACE.

2. 02

   File EAS through SUACE (days 1–10)

   Online via eas.mic.gov.py. SUACE bundles Registro Público de Comercio, RUC issuance, IPS registration and municipal patente in a single workflow. Published target: 72 hours. Realistic with paperwork in order: 5–10 business days.

3. 03

   Open the bank account (weeks 2–6)

   The actual bottleneck. Itaú, Continental, GNB, Sudameris and Banco Familiar all onboard EAS clients; KYC for non-resident shareholders has tightened post-FATF mutual evaluation. Plan for 2–4 weeks of compliance review with notarised incorporation docs, beneficial-ownership disclosure, business plan and source-of-funds documentation.

4. 04

   Apply for the Investor Pass (parallel)

   If pursuing permanent residency: file the Constancia de Inversionista Extranjero with MIC under Resolución 0283/2026. CIE target is 5 business days from a complete file. The DNM permanent-residency card follows in 3–6 months. *See Investor Pass for the four tracks.*

5. 05

   Operate (week 4+)

   Monthly accounting from US$ 200–500 depending on regime. IPS contributions for any local hires (employer 16.5%, worker 9%). Annual IRE filing. PR-card holders maintain status with at least one visit every three years.

This is the standard path. The Investor Pass productive track explicitly requires substance (rent, salaries, recurring admin costs do not count toward the US$ 70,000 investment computation), so a shell entity used purely to qualify for residency is grounds for revocation. Plan on real operations.

Honest caveats

Five things we won't pretend away.

• Banking is the real friction.

  Incorporation is cheap and quick. The bank account is where post-2022 FATF compliance lands hardest on non-resident-controlled entities. Budget 2–4 weeks and prepare documentation thoroughly.

• Territoriality is real but not magic.

  Foreign-source income is exempt at company level. Personal IRP and BEPS-style structuring still apply if you tax-reside in Paraguay personally. The "live here, earn abroad, pay zero" pitch needs a real Paraguayan accountant — not a Twitter thread.

• Substance over paper.

  MIC, DNIT and SUACE increasingly cross-check whether companies used to qualify for the Investor Pass have actual employees, leases and utilities. A paper-only entity is a red flag and grounds for CIE revocation.

• Transfer pricing applies.

  Effective 1 January 2021 under Decreto 4644/2020 + Ley 6380. Related-party deals with foreign parents — especially counterparties in low-tax jurisdictions or FTZ users — are scrutinised. Mandatory Technical Study if gross revenue exceeded PYG 10 bn the prior year.

• Currency is stable but not pegged.

  BCP publishes a daily reference rate; PYG was at 6,095.94/USD on 22 May 2026 — the guaraní has appreciated ~24% against the dollar over the last twelve months. Local hires invoice and receive payment in guaraní; foreign-paid contractors typically hold USD accounts.