Representatives from the import and micro, small, and medium-sized business sectors expressed support for the increased transparency required by the Dirección Nacional de Ingresos Tributarios (DNIT) regarding corporate reserves, but categorically rejected the possibility of any law taxing undistributed profits.
DNIT’s Resolution No. 49/2026, already in effect, is at the center of debate among Paraguayan business leaders. The regulation establishes new reporting requirements on the formation and use of companies’ optional reserves, including details on their purpose and the corresponding equity backing.
Iván Dumot, president of the Centro de Importadores del Paraguay (CIP), said the resolution falls within DNIT’s authority and viewed the measure positively. “We understand it is a correct resolution. It includes certain improvements we proposed to the institution, such as detailing how the reserves are used or for what purpose they are established. This is information that, in some cases, is private and may require confidential treatment,” he said.
Dumot explained that the regulation aims to provide greater clarity on how reserves are formed, whether they are properly formalized, and if there has been any disguised profit distribution, which would be penalized. He added that a more thorough review could even lead to recommendations for some companies to strengthen their capitalization, although this would not have a direct tax effect.
Meanwhile, Luis Tavella, head of the Federación de Micro, Pequeñas y Medianas Empresas (Fedemipymes), agreed that the resolution promotes greater transparency in reserve management. However, he noted that DNIT’s intervention comes at a time when the state is seeking to increase revenue given the current fiscal situation. “I believe DNIT’s intervention is driven by the potential revenue identified in non-capitalized reserves,” he said.
Both sectors warned that any law limiting companies’ ability to decide on these resources would represent a serious state intervention in decisions that belong to shareholders. Dumot questioned the possible imposition of a deadline to hold reserves without distribution, with a tax obligation upon expiration. “That would condition companies’ strategic and equity decisions to a fiscal situation, and that is not the spirit of the law,” he argued.
The CIP president reiterated that tax on profit distribution should only be paid when profits are actually distributed, regardless of whether the company decides to retain them for one, two, five years, or whatever period it deems prudent. Dumot stated that the current regulation already provides DNIT with sufficient tools for better oversight of reserve treatment and that, as long as there is no misuse to conceal dividends, the tax authority has no grounds to impose sanctions or fines.
According to Dumot, based on explanations received from DNIT, there is currently no bill under discussion in Congress to impose new taxes on corporate reserves.