Paraguay mandates crypto wallet declaration

The National Tax Directorate of Paraguay has required cryptocurrency platforms and individuals holding digital assets to submit annual reports detailing all digital asset activity. This move reshapes the compliance landscape for a country that attracted a record 47,687 residency applications in 2025, partly due to its open approach to the cryptocurrency sector.

General Resolution No. 47/2026, signed by the Director of the National Tax Directorate (DNIT) Óscar Alcides Orué Ortíz on 10 March, establishes what the agency calls an “obligation to provide information on all transactions carried out with crypto assets.”

Reporting will be conducted through the DNIT’s existing Marangatu tax management system, with the first reporting period scheduled for early 2027 for the 2026 fiscal year.

Who must report and what to report

Two groups fall within the scope. Platforms operating in Paraguay must report all user transactions, regardless of size. Resident individuals and entities with annual crypto activity exceeding US$5,000, calculated individually or in total, must personally file a sworn information return on crypto assets (Declaración Jurada Informativa de Criptoactivos) when transacting through non-resident platforms or via peer-to-peer transactions without intermediaries.

Data requirements are highly detailed. For each transaction, the reporter must disclose the date and time, counterparty identity (or wallet address if the identity cannot be determined), crypto asset name, ticker symbol and blockchain network, quantity precise to 10 decimal places, total value in USD, all transaction and gas fees, and the transaction hash along with source and destination addresses.

In cases where the counterparty identity can be determined, the resolution requires the reporter to provide full name, nationality, tax address, and tax identification number.

“Resolution No. 47/26 should be a wake-up call for every Bitcoin holder who has established tax residency in Paraguay and assumed the job was done,” remarked Adam Juchniewicz, CEO of Bitcitizen.

According to him, “Paraguay’s territorial tax system did not change overnight, but the reporting infrastructure built around it has. The ability to monitor is a prerequisite for taxation, and the DNIT has just equipped itself with eyes.”

Scope broader than most

Article 2 of the resolution defines “crypto assets” as any digital representation of value or rights secured by cryptography on a distributed ledger, explicitly including value tokens, 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.

The definition of “platform” is equally broad, including centralised exchanges (CEX), decentralised exchanges and DeFi protocols (DEX/DeFi), custodial and non-custodial wallets, NFT marketplaces, staking and lending services, smart contracts, and “any other technological mechanism” that facilitates crypto transactions, regardless of whether the entity holds a financial licence.

“The cold wallet defence argument—that your hardware wallet is outside Paraguayan territory and therefore outside the tax net—has theoretical validity under the current territorial framework,” Juchniewicz noted. “But theory does not hold up in a regulatory environment that now requires platforms to provide wallet addresses and transaction hashes. Once the state can trace the flow of funds, the burden of proof shifts to the user.”

Identifying the trend

Paraguay is not a participant in the OECD’s Common Reporting Standard (CRS), a feature that has made the country attractive to globally mobile individuals seeking financial privacy.

Resolution 47/26 does not change that status. What it does is build a domestic surveillance architecture for crypto, parallel to what the OECD’s Crypto-Asset Reporting Framework (CARF) is building at the international level—48 jurisdictions began collecting CARF data on 01 January 2026, with the first exchange scheduled for 2027.

“We have seen this scenario before: Portugal, the UK’s non-dom regime, and now Paraguay,” Juchniewicz said.

According to him, “the trend is consistent: a territory attracts capital through preferential tax policies, the number of beneficiaries grows, and the government eventually closes the door. Bitcoin holders are legally exploiting structural loopholes, but legislators always catch up. Technology only gives you a head start, not a permanent exemption.”

This resolution does not create new taxes. Its preamble frames the measure as the exercise of existing DNIT powers to “identify economic activities with crypto assets in the context of their increasing economic importance,” while asserting that “full identification and tracking will enhance control, supervision, and compliance with tax obligations.”

Many reports describe this as phase one of a broader programme, with tax and enforcement phases expected during the remainder of 2026.

Late filing incurs a fixed penalty of 1,000,000 guaraní (approximately US$130). Paraguayan residents who meet the reporting threshold but do not yet have a tax identification number (RUC) must register separately to comply with the regulation.

Implications for advisors

Paraguay’s territorial tax system only taxes domestic-sourced income at 10%, while the residency pathway via the SUACE programme only requires a US$70,000 investment in a local business over 10 years. This combination has made Paraguay a preferred choice for cryptocurrency holders seeking tax-efficient residency, especially since Paraguay modernised its immigration laws in late 2025.

“For residency-by-investment consultants introducing Paraguay to crypto clients, the due diligence obligation has just become more onerous,” Juchniewicz warns. “You cannot sell a 0% tax residency solution and walk away, not when the DNIT is clearly aligning with FATF standards and the global CARF reporting framework is already active in 48 territories. The era of ‘set and forget’ crypto tax planning across territorial jurisdictions is closing rapidly.”

This resolution runs in parallel with Law 7572/2025, Paraguay’s new Securities and Products Market Law, which assigns the supervision of tokenised assets to the Securities Supervisory Authority (SIV). The DNIT’s authority, by contrast, extends to all cryptocurrency transactions, including decentralised assets used as a medium of exchange. Two regulators, two directions, one ecosystem under increasingly tight scrutiny.