The recent regulation of the new maquila regime introduces significant changes in the operation and control of thesystem, consolidating an evolution that has been observedin administrative practice. Beyond its technical nature, Decree No. 7547/2026 marks a shift toward a more structured and digitalized model, with greater traceability ofoperations.
Below are the main points to consider from a practicalperspective.
Digitalization and Centralization of the Regime
One of the central axes of the regulation is theimplementation of a comprehensive computer system formanaging the maquila regime. This system not onlychannels the submission and approval of programs but alsoincorporates modules for registering operations, generatingreports, and controlling inventories.
Additionally, it is planned to connect this system with othergovernment entities, enabling a much more efficient cross-control scheme.
In practical terms, this implies a reduction in operationaldiscretion but, at the same time, increased exposure todata-based oversight.
The Maquila Current Account as a Control Tool
The system of current accounts is formalized tocomprehensively record the flow of goods and operations: temporary imports, exports, nationalizations, re-exports, losses, waste, among others.
This system must maintain consistency both with the company’s accounting records and with the data registered with the National Directorate of Tax Revenues (DNIT).
Consequently, the regime operates under a logic of complete traceability, where any deviation between physical inventory, accounting records, and declarations can generate contingencies.
Greater Accounting Requirements
The regulation explicitly incorporates the obligation to keep records in accordance with International Financial Reporting Standards (IFRS), as well as the ongoing consistency between the computer systems and accounting.
This raises the technical standard of the regime, shifting it from a merely operational approach to one with a strong component of accounting and documentary compliance.
Consolidation of Service Maquila
The inclusion and operation of the service maquila are confirmed, establishing that exportation is configured at the moment of invoice issuance, which must be issued without VAT.
This recognition represents a significant advance, in line with the evolution of the regime. While service maquila is acknowledged, there is no in-depth discussion of the minimum levels of economic substance required in Paraguay or its proper alignment with the general VAT territoriality rules, which could lead to interpretative gaps in practice.
Strengthening of the CNIME’s Role
The National Council of Export Maquiladora Industries (CNIME) takes on a central role not only in program evaluation but also in defining additional requirements related to employment, investment, training, or technology use.
Although this allows alignment of the regime with public policy objectives, the absence of pre-defined objective parameters introduces a degree of discretion that may impact the predictability of the approval process.
Recognition of Limited Maquila Modalities
While the decree reaffirms figures such as submaquila and shelter (or hosting), it does not introduce specific operational development but refers to the definitions provided in the law and defers regulation of their conditions to bi-ministerial resolutions. Consequently, their practical application remains limited.
Generally speaking, these are well-known schemes: submaquila as outsourcing part of the production process, and shelter as the use of a local structure by a foreigner. However, the decree does not clarify essential aspects for their implementation.
Recognition of Mixed Operations
The regulation expressly admits the coexistence of operations under the maquila regime and the general regime. However, it requires separate accounting records that clearly identify the income and expenses of each type of operation.
This recognition is positive from an operational standpoint but increases compliance complexity.
Continuity of the Temporary Import Benefit with Greater Control
The suspension of import taxes for goods entered under the regime is maintained, but control mechanisms are reinforced, including the requirement for guarantees and the possibility of physical inspections and audits by DNIT.
This confirms a trend toward strengthening control without altering the substantive benefit of the regime.
Regulation of Wastes and Discards
More detailed rules are established for handling wastes and discards, allowing their destruction, donation, or re-export under certain conditions and with prior authorization.
This aspect, which has historically been more flexible in practice, is now formally regulated, involving technical agencies such as the National Institute of Technology and Standardization (INTN).
Recovery of VAT Credit
The right to recover VAT credit related to maquila operations is recognized, although the procedures regulation is delegated to DNIT.
Therefore, while the right is provided, its practical implementation will depend on subsequent regulations.
General Considerations
The regulation of the new maquila regime represents a significant step forward in modernization and control, establishing a more transparent, traceable system aligned with international standards.
However, it also introduces increased compliance requirements and leaves certain areas open, some subject to future regulation and others to short-term administrative interpretation.
In this context, designing and implementing maquila structures will require an increasingly comprehensive approach that combines operational, accounting, tax, and customs aspects.
Para más información, contacte con Luciano Antonelli: luciano.antonelli@berke.com.py y/o Ma. Julia Méndez: julia.mendez@berke.com.py y/o Federico Valinotti: federico.valinotti@berke.com.py
