Paraguay stands out amongst most South American countries as being the one most at risk of substantial jurisdictional top-up tax for in-scope groups under Pillar Two.
Its standard rate of corporate income tax is 10% under Article 21 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System. This is in contrast to other South American jurisdictions that have much higher standard rates of corporate income tax, such as:
Brazil – 34%
Argentina – 35%
Chile – 27%
Peru – 29.5%
Columbia – 35%
Venezuela – 34%
Guyana – 40%
Mexico – 30%
Nicaragua – 30%
Ecuador – 25%
Bolivia – 25%
Uruguay – 25%
Article 1 of Law No. 6,380/19 on the Modernization and Simplification of the National Tax System establishes a territorial basis for corporate income tax in Paraguay. As such, only income from Paraguayan sources is taxable, subject to a number of exceptions. For instance, Article 6 of Law 6,380/19 provides that Paraguayan source income includes:
If you haven’t got a subscription you can join up below.
On October 28, 2025, Government Notice No. 6763 was issued which extended some of the Pillar 2 filing and notification deadlines.
On October 29, 2025, Order HAC/1198/2025, of October 21 was published in the Official Gazette. This approves the final versions of three specific Pillar 2 forms – Form 240 (registration), Form 241 (the GIR) and Form 242 (the top-up tax return).
On October 21, 2025, Slovakia’s Parliament approved a law to amend its minimum tax act to provide for the June 2024 and January 2025 OECD Administrative Guidance, as well as EU Directive DAC 9 amendments.
On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns.
Guernsey has issued the Guernsey Pillar 2 Brief: Issue 1 which includes further detail on the registration process (the actual registration system is planned to be operational during the fourth quarter of 2025).
On October 14, 2025, France released the 2026 Finance Bill. This includes amendments to include the June 2024 OECD Administrative Guidance, as well as DAC 9 implementation.
On October 14, 2025, France released the 2026 Finance Bill. This includes amendments to include the June 2024 OECD Administrative Guidance, as well as DAC 9 implementation.
On October 2, 2025, Hungary released the 2025 Autumn Tax Package. This includes some amendments to the operation of the Transitional CbCR Safe Harbour.
On October 15, 2025, Hungary issued the draft Advance QDMTT Tax Declaration (Form 24GLBADO) as well as filing instructions and a draft XML guide.
On October 10, 2025, Belgium issued a Draft Law to amend its Minimum Tax Act. There are a number of technical amendments (which don’t effect the Minimum Tax calculation), the correction of an error in the original text as well as administrative amendments.
On October 3, 2025 Normative Instruction RFB No. 2282, of October 2, 2025 was published in the Official Gazette. This includes amendments to Brazil’s DMT Law for the OECD June 2024 OECD Administrative Guidance and other sundry amendments.
On October 5, 2025, Israel published a consultation on a draft law for a domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax or ‘QDMTT’) from January 1, 2026.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2025 OECDPillars
All Rights Reserved
