On October 14, 2024, the Agreement between Spain and Paraguay aimed at avoiding double taxation and preventing tax evasion in matters of income taxes officially came into force. This significant development, published in the Official State Gazette on July 29, is designed to enhance economic relations, stimulate investments, and strengthen bilateral cooperation in tax matters between the two nations.
The Agreement is part of a broader strategy to ensure fair taxation and prevent opportunities for non-taxation or reduced taxation through evasion tactics, including the abusive use of treaties by third parties. It sets forth clear guidelines on the taxation of various income sources, including real estate, business profits, dividends, interest, royalties, and capital gains, while also covering aspects like dependent personal services, director remuneration, and pensions. The standards incorporated into this Agreement align with those of the Organization for Economic Cooperation and Development (OECD).
The negotiation of this Agreement began between 2013 and 2014, with several key milestones coinciding with official visits by Paraguayan presidents to Spain. Notably, the final agreement was reached in Madrid during the third round of negotiations on November 7, 2022, shortly after an official visit by Paraguay’s then-president, Mario Abdo Benítez. During this visit, Abdo Benítez underscored the importance of Spanish investments in Paraguay’s economic development and highlighted the forthcoming implementation of the bilateral tax agreement as a major competitive advantage for attracting investors to Paraguay.
The signing of the Double Taxation Agreement was authorized by Spain’s Council of Ministers on February 28, 2023, and subsequently signed in Santo Domingo, Dominican Republic, on March 25, 2023. The Council of Ministers forwarded the text to the Cortes Generales just days before the current president of Paraguay, Santiago Peña, made his first official visit to Spain.
During his visit, President Peña emphasized Paraguay’s potential as a prime investment destination for Spanish companies. At the Spain-Paraguay Business Meeting, organized by the Spanish Confederation of Business Organizations (CEOE), Peña reassured Spanish investors that Paraguay offers a simple and attractive tax regime conducive to job creation and that there were no plans to raise taxes. He also acknowledged the significant role that Spanish companies play in Paraguay’s economic growth, making Spain the fifth-largest foreign investor in the country.
This Agreement represents a critical step in bolstering economic ties between Spain and Paraguay, providing a solid foundation for future collaboration and investment, and ensuring that both nations can enjoy the benefits of a more integrated and cooperative tax environment.
Source: The Diplomat in Spain
