Maquiladora Regime in Paraguay

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www.pwc.com/py Maquiladora Regime in Paraguay Benefits to obtain a competitive advantage

Regulatory backgrounds The Maquila business in Paraguay The detailed regulations of Law 1064/97 On the Maquiladora export industry were issued in July, 2000, with the objective of promoting the establishment and regulating the operations of maquiladora companies fully or partially engaged in production processes in Paraguay, which add value to the nation by combining temporarily imported foreign goods and services with national labor and other resources, the product of which is intended for export. Currently, the Maquila business in Paraguay is operational and in full expansion with more than 85 Maquiladora companies having foreign capital ownership. Which is the regulatory authority? Such activity requires the approval of CNIME, prior to export and to this effect, periodic reports are filed detailing raw material consumption, among other formal requirements. The origin of Maquiladora products In order to qualify for a certificate of MERCOSUR origin, Paraguay requires a minimum 60% regional (including Paraguay) added value plus a 40% extrazone added value. However, if the transformation process of goods within Paraguayan territory utilizing materials not originated from MERCOSUR countries achieves differential singularities for the product, it may qualify for the certificate of national origin provided a new tariff item is recognized by the authorities. The Maquiladora activity is subject to the regulations of the National Council of Exporter Maquiladora Industries (acronym CNIME). The CNIME oversees the import of raw materials for transformation and subsequent export.

Main features Involved actors The regime is oriented to a model that consists of a head office and a maquiladora that operates in Paraguayan territory, where it is understood the following: Head office Contractor residing abroad. Maquiladora Contracted, domiciled in any part of the Paraguay territory. Main features Maquiladora Regime Under a contract signed with the foreign head office, the Maquiladora carries out the partial or complete production of goods for export, or provides the service for export to foreign beneficiaries. The Maquiladora may, in turn, subcontract certain processes specifically foreseen in the program of the Maquila contract with another company (the Sub-maquiladora. The head office may provide to its Maquiladora capital goods, raw materials and production inputs, directly or via other countries. The Maquiladora may contract the provision of goods, services, labor and other similar items within Paraguayan territory. The products resulting from the Maquila service are returned to the head office, or sent on behalf of it to a client domiciled in any location worldwide.

Main benefits The companies that operates in Paraguay under the Maquila regime, could generate important benefits, which can be formalized with an adequate management of the variables involved in a constitution and operation process in Paraguayan territory, find below a summary of them: Unified Tax at 1%- rate VAT Recovery The operations under the Maquila regime are exempted from all taxes or rates related to the production process. This tax substitutes Corporate Income Tax, and is levied either on the value added within Paraguayan territory or on the export price. The Maquiladoras are exempted from Value Added Tax (VAT) on their exports of products or goods. They may recover the VAT paid on their purchases of goods and services in the form of Fiscal Credits, which may be applied to the payment of various taxes or transferred to third parties. Suspension of import tariffs The Maquila regime enables companies to import raw materials, machinery and the necessary inputs under a temporary admission system which is exempt from import tariffs and taxes. Dividend remittances abroad Maquiladoras are exempt from any tax or rates on dividend remittances abroad. Other tax exemptions Customs Valuation Service fees. Consular fees. Port charges (50%) and Airport taxes. All taxation, rates and contributions levied on the guarantees. Usted puede dedicar Taxes, rates and contributions levied on tiempo a su negocio, borrowings to finance Maquila's operations. Other tax exemptions nosotros (Municipal nos ocupamos service rates, VAT levied on rental del resto. or leasing for equipment forming part of the Maquila Program).

Why invest in Paraguay? Paraguay today is one of the countries in the region with the best macroeconomic profile, it has a very favorable environment for foreign investments due to the competitiveness from the perspective of both tax and labor costs, as well as certain components that are fundamental to production and/or Maquila, such as: energy costs, transportation, labor, among others.

How can we support you? Paraguay has professionals with extensive experience in Tax, Legal, Outsourcing and Consulting business matters (Consultancy in financial, human resources, business plans, market studies, among others), our knowledge in local regulations allows us to support our clients effectively and with high quality standards. In that sense, we have the skills to accompany our clients throughout the joining Maquila Regime process and the viability analysis. In addition to this, we are able to support in: setting up the company, the start-up and the day-to-day operation: Legal and Operational viability analysis Legal and Operational corporate constitution support Start-up Support Kind of Company applicable to the operation to be developed. Determination of the tax benefits and impacts. Legal and tax restructurings analysis. Financial Business Plan elaboration. Market researchs. Company's constititution and registration in the Public Registries. Support for obtaining the Taxpayer card. Registration before the Labor authorities and social security. Search and identification of Chief Executives. Assistance to obtain Paraguayan residence for expats. (Work permit). Project governance and Tax Services. Loan of staff (For Accounting, Human Resources and Finance matters). Headhunting. Software searches. Monitoring the necessary activities for the start-up. Operations support Tax returns review and filing. Tax returns elaboration and filing. Outsourcing of Accounting services. Payroll service. HR tasks support. Internal Audit tasks support

Contacts Nadia Gorostiaga Associate Partner TLS Paraguay nadia.gorostiaga@py.pwc.com Boris Mercado Partner Advisory Paraguay mercado.boris@py.pwc.com Daniel García Partner TLS Uruguay daniel.garcia@uy.pwc.com Nathalia Rivas Manager TLS Paraguay nathalia.rivas@py.pwc.com URUPABOL Lorenzo Franzini Manager URUPABOL Desk in San Pablo franzini.lorenzo@pwc.com Sergio Fischer Partner Santa Cruz, Bolivia sergio.fischer@bo.pwc.com Gonzalo Ariscain Partner La Paz, Bolivia gonzalo.ariscain@bo.pwc.com Usted puede dedicar tiempo a su negocio, nosotros nos ocupamos del resto. www.pwc.com/py PricewaterhouseCoopers, Av. Santa Teresa 1827 y Aviadores del Chaco Paseo La Galería Piso 21. T:+595(21)418 8000 - Asunción, Paraguay, www.pwc.com/py 2018 PricewaterhouseCoopers. Todos los derechos reservados. refiere a la sociedad civil paraguaya PricewaterhouseCoopers y en algunas ocasiones a la red. Cada firma miembro es una entidad legal separada. Por favor visite pwc.com/structure para más detalles.