Paraguay’s national tax authority has ordered crypto platforms and individual holders to file detailed annual returns on all digital asset activity, a move that reshapes the compliance calculus for a country that attracted a record 47,687 residency applications in 2025, partly on the strength of its hands-off approach to crypto.
Resolución General N.° 47/2026, signed on March 10 by Dirección Nacional de Ingresos Tributarios (DNIT) Director Óscar Alcides Orué Ortíz, establishes what the authority calls “the obligation to supply information on all transactions carried out with crypto-assets.”
Reporting will flow through the DNIT’s existing Marangatu tax management system, with the first filings due in early 2027 for the 2026 fiscal year.
Who Reports, and What
Two categories of filers fall within the scope. Platform operators inside Paraguay must report on every user transaction, regardless of size. Resident individuals and entities whose annual crypto activity exceeds US$5,000, whether individually or in aggregate, must file their own sworn informational return (Declaración Jurada Informativa de Criptoactivos) when they transact through non-resident platforms or peer-to-peer without any intermediary.
The data requirements are granular. For each transaction, filers must disclose the date and time, counterparty identity (or wallet addresses where identity cannot be determined), the crypto asset’s name, ticker, and blockchain network, quantity to ten decimal places, gross value in US dollars, all fees and gas costs, and the transaction hash with origin and destination addresses.
Where counterparties can be identified, the resolution requires that filers provide full names, nationality, tax domicile, and taxpayer identification numbers.
“Resolution No. 47/26 should be a wake-up call for every Bitcoiner who set up a Paraguayan tax residency and assumed the job was done,” observed Adam Juchniewicz, CEO of Bitcitizen.
He says that “Paraguay’s territorial tax system hasn’t changed overnight, but the reporting infrastructure being built around it has. Visibility is the precursor to taxation, and the DNIT just gave itself eyes.”
Scope: Broader Than Most
Article 2 of the resolution defines “crypto-asset” as any cryptographically secured digital representation of value or rights on a distributed ledger, explicitly naming tokens of value, utility tokens, stablecoins, and non-fungible tokens (NFTs). Only central bank digital currencies (CBDCs) and instruments already regulated under Paraguay’s securities laws fall outside the scope.
Equally broad is the definition of “platform.” The resolution captures centralized exchanges (CEX), decentralized exchanges and DeFi protocols (DEX/DeFi), custodial and non-custodial wallets, NFT marketplaces, staking and lending services, smart contracts, and “any other technological mechanism” facilitating crypto transactions, regardless of whether the entity holds a financial license.
“The cold storage defense, arguing that your hardware wallet is outside of Paraguay and therefore outside the tax net, has theoretical merit under the current territorial framework,” Juchniewicz noted. “But theory doesn’t survive a regulatory environment that now requires that platforms hand over wallet addresses and transaction hashes. Once the state can trace the flow, the burden of proof shifts to you.”
Pattern Recognition
Paraguay does not participate in the OECD’s Common Reporting Standard (CRS), a distinction that has made it attractive to globally mobile individuals seeking financial privacy.
Resolution 47/26 does not change that status. What it does is construct a domestic surveillance architecture for crypto that parallels what the OECD’s Crypto-Asset Reporting Framework (CARF) is building internationally; 48 jurisdictions began collecting CARF data on January 1, 2026, with first exchanges due in 2027.
“We’ve seen this movie before: Portugal, the UK non-dom regime, now Paraguay,” Juchniewicz said.
He says the “pattern is consistent: a jurisdiction attracts capital through favorable tax treatment, the population of beneficiaries grows, and the government eventually moves to close the door. Bitcoiners are legally taking advantage of structural oversights, but legislators always catch up. The technology just buys you a head start, not a permanent exemption.”
The resolution does not create new taxes. Its preamble frames the measure as an exercise of DNIT’s existing powers to “identify economic operations with crypto-assets in view of their growing economic relevance,” adding that “adequate identification and tracking will strengthen control, oversight, and compliance with tax obligations.”
Multiple reports, including coverage by Bitcoin Magazine and CriptoNoticias, describe this as phase one of a broader program, with taxation and enforcement phases expected through the remainder of 2026.
Late filing carries a flat fine of ₲1,000,000 (approximately US$130). Paraguayan residents who meet the threshold but lack a taxpayer registration (RUC) must register specifically to comply.
What It Means for Advisors
Paraguay’s territorial tax system taxes only domestic-source income at a flat 10%, while its residency pathway through the SUACE program requires just US$70,000 invested in a local business over ten years. That combination has made it a go-to recommendation for crypto holders seeking tax-efficient residency, particularly since Paraguay modernized its migration law in late 2025.
“For investment migration advisors recommending Paraguay to crypto clients, the due diligence obligation just got heavier,” Juchniewicz warned. “You can’t sell a 0% tax residency and walk away, not when the DNIT is explicitly aligning with FATF standards and the global CARF reporting framework is already live in 48 jurisdictions. The era of set-it-and-forget-it crypto tax planning through territorial jurisdictions is closing fast.”
The resolution runs parallel to Law 7572/2025, Paraguay’s new Securities and Products Market law, which assigns oversight of tokenized assets to the Securities Superintendency (SIV).
DNIT’s authority, by contrast, extends to all crypto transactions, including decentralized assets used as a medium of exchange. Two regulators, two tracks, one ecosystem under tightening scrutiny.
