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.
Law 3/2025, of 29 April, was published in the Spanish Official State Gazette on April 30, 2025. This amends the Economic Agreement with the Basque Country and includes a new Article 20bis for the application of the Pillar 2 Global Minimum Tax.
In this article we look at some of the most significant issues to consider including the determination of when and how deals can bring groups within the scope of Pillar Two, specific considerations for private equity funds, differences in GloBE and domestic tax treatment and potential restrictions on post-acquisition transfers.
The Pillar Two GloBE treatment of corporate investments will depend to a large extent on the nature of the activities, the accounting treatment and the ownership interest.
On April 30, 2025, the Swiss Federal Council issued a proposal to amend the Minimum Tax Ordinance to provide for the OECD GIR provisions, as well as some other small amendments.
On March 31, 2025, Japan enacted Cabinet Order No. 121 of 2025 and Ministry of Finance Ordinance No. 19 of 2025 to provide further details on the application of Japan’s QDMTT from April 1, 2026.
In April 2025, the Hong Kong Government proposed a number of Committee Stage Amendments to the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024. This includes amendments for the January 2025 and June 2024 OECD Administrative Guidance.
South Korea’s amendment to the Enforcement Decree No. 35348 of February 28, 2025 and the Decree of the Ministry of Economy and Finance No. 1114 of March 21, 2025 provide for further aspects of the June 2024 OECD Administrative Guidance as well as additional top-up tax forms.
Updates to our ‘OECD Administrative Guidance: Domestic Implementation Matrix’ to reflect the latest April 2025 Pillar 2 updates for the UAE and Poland.
On April 7, 2025, the Polish Ministry of Finance released details for a draft bill to amend the Minimum Tax Act. The amendments are primarily to implement the June 2024 and January 2025 OECD Administrative Guidance.
On April 16, 2025, the Ministry of Finance issued Ministerial Decision No. (88) of 2025 to provide for the application of the OECD Administrative Guidance from January 1, 2025.
The UTPR exclusion for MNEs in their initial phase of international activity does not need to be included in a QDMTT, however, it can be included. In this article we look at the different jurisdictional approaches.
On January 15, 2025, the OECD issued Administrative Guidance that includes a list of jurisdictions that have transitional qualified status for the purposes of the income inclusion rule and domestic minimum tax (including the QDMTT Safe Harbour). This was subsequently updated on March 31, 2025.
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
