Paraguay Double Tax Treaties: The Full List, Sourced and Dated

The Treaty Table

The table below is built from two official sources: DNIT's published list of treaty-approval laws, and the bilateral-treaty status table (the Listado de Vigencia) maintained by the foreign ministry and hosted by DNIT. Anything not in those sources does not appear here.

Full double tax treaties, in force

Transport-only treaties (not general double tax treaties)

Four older agreements cover only international transport income: air transport with Uruguay (Law 55/1991) and Germany (Law 1087/1984), air transport with Belgium (Law 1236/1987), and air, river, and land transport with Argentina (Law 1105/1997). They matter to airlines and shipping operators, not to residents with investment or business income. Listing them as "double tax treaties," as some summaries do, inflates the count.

Signed but not in force

Two more belong on the record for completeness. Paraguay and Brazil signed an income treaty in Brasilia in September 2000, but the Paraguayan Congress never approved it, so it has no effect. And in 2025 Paraguay and Chile signed an updated convention to replace their 2006 treaty; until it is approved and ratified by both sides, the existing treaty keeps applying. Treaties you read about at signing stage are not treaties you can use yet.

How Tie-Breakers Decide Dual Residency

Dual residency is rare, but when it happens the bill arrives twice. If you count as resident in both Paraguay and a treaty country in the same year, the treaty does not split your income; it runs a fixed cascade of tests, and the first test that produces an answer settles your residency for that treaty. Paraguay's treaties follow the standard structure:

1. Day count. More than 183 days spent in one of the two countries during the year decides it.
2. Permanent home. If the day count is ambiguous, the country where you have a permanent home available wins. A home in each country means the test cannot decide and you move on.
3. Center of vital interests. Family and economic ties, weighed together. A spouse and children in one country, or the core of your business activity there, usually settles it here.
4. Habitual residence. Where you actually live in the ordinary course, as a pattern rather than a count.
5. Citizenship. The last tie-breaker before the treaty gives up.

If every test fails to decide, the case moves to the mutual agreement procedure (MAP): the two tax authorities negotiate the outcome between themselves, government to government. You cannot trigger MAP on your own, and you cannot pick the test that suits you. The practical defense is to avoid the ambiguity in the first place, which means building the Paraguay side so clearly that the cascade never needs to run: cédula, RUC, filings, and real presence, and a home-country exit done by the book.

The Spain Treaty, the One That Changed the Numbers

The 2024 Spain treaty is the most consequential one for foreign residents, because Spain is a country that both taxes worldwide income and has an established expatriate and investor community in Paraguay. It was signed in March 2023, approved by Paraguay through Law 7143/2023, ratified by Spain on 29 July 2024, and entered into force on 14 October 2024, first applying to tax periods from 2025.

The rate changes are concrete. Dividend withholding from Paraguayan companies drops from the 15% non-resident rate to 5% for a company beneficial owner holding more than 50% of the payer, or 10% otherwise. Interest and royalties are capped at 5%. For a Spanish shareholder of a Paraguayan company, that is a permanent reduction in the cost of moving profits out, and it is the number to check any legacy advice against.

If you are Spanish and weighing Paraguay, the treaty does not change the residency analysis itself: becoming tax resident still runs through the cédula, the RUC, and real presence. What the treaty changes is what happens to the Paraguay-source slice of your financial life once you are here.

When No Treaty Is the Simpler Exit

People assume a missing treaty is a hole in the plan. For the exit itself, it is usually the opposite. A treaty only helps you when you need to win a tie-breaker against your old country; with no treaty in place, there is no tie-breaker to fail, and your exit runs entirely on your old country's domestic rules. Most countries release tax residency once two things are true: you are out of the country more than 183 days a year, and you hold a genuine new tax residency with documents behind it. A Paraguay built on a cédula, a RUC, and monthly filings satisfies the second condition cleanly.

The choice of replacement residency also reads differently to an origin-country reviewer. The United Arab Emirates appears on watch lists and blacklists maintained by a number of origin countries, which means an UAE certificate invites extra scrutiny in exactly the files where you least want it. Paraguay does not appear on those lists, so a Paraguay tax residency certificate lands as an ordinary document rather than a flagged one.

One caution from the German files: leaving without anywhere to land is not the same as leaving well. Germans who deregister (Abmeldung) and then sit stateless, with no new tax residency anywhere, often find the problem does not surface immediately; in practice it tends to surface one to three years later, when banks start asking origin-of-funds questions and there is no certificate to answer with. Treat that window as a practice estimate, not a rule. The safer sequence is to build the Paraguay side first, then cut ties. The country-by-country steps are in our breaking tax ties guide.

How We Help

Treaty positioning is a small part of the picture that belongs to people who look at the whole picture. If you have Paraguay-source income, a Spanish passport, or a structure built before October 2024, the treaty layer is worth a conversation before the next filing season. For the monthly work that keeps your Paraguay side defensible either way, our accounting services and advisory service cover it end to end.