On March 10, 2026, the DNIT (Paraguay's tax authority) issued Resolución General N.° 47/2026, a new reporting requirement that applies to anyone residing in Paraguay who operates with crypto-assets above US$5,000 per year.

This isn't a tax. Paraguay still has 0% tax on foreign-sourced crypto income under its territorial system. That hasn't changed. But the reporting obligation is brand new, and if you hold or trade crypto as a resident of Paraguay, this directly affects you.

Starting with the 2026 tax year (with first filings due in early 2027), residents who operate with crypto-assets must file a sworn informational return, called a Declaración Jurada Informativa de Criptoactivos, disclosing detailed information about their activity.

That includes wallet addresses and blockchain networks used, transaction hashes with exact dates and times, the amount and USD value of every transaction, fees and gas paid, and counterparty information. The scope covers buying, selling, trading between cryptocurrencies, mining, staking, yield farming, airdrops, lending income, payments, and even transfers between your own personal wallets.

In short, if you personally operate with crypto in Paraguay above the $5,000 threshold, the government wants a complete picture of what you're doing, where you're doing it, and with whom.

The resolution applies to "personas físicas o jurídicas residentes o domiciliadas en el país que operan con criptoactivos" — natural persons or legal entities resident in Paraguay that operate with crypto-assets.

The trigger word here is "operan," which means "operate." Not "poseen" (possess or own), and not "controlan entidades que operan" (control entities that operate). The obligation falls specifically on residents who personally operate with crypto. This distinction matters.

If you, as an individual resident in Paraguay, are buying and selling crypto on exchanges under your own name, you are operating with crypto-assets. You fall within the resolution and will need to report.

As the resolution is currently written, holding and trading crypto under a properly structured offshore entity means that activity falls outside the scope of the reporting requirement. The entity is the one operating with crypto. You are not.

The structure that fits this best is a Panama Private Interest Foundation (PIF). A PIF is a legal entity under Panamanian law that has no owners and no shareholders.

Assets transferred to it become the foundation's separate legal property, legally distinct from the person who set it up. The foundation is a Panamanian entity, not resident or domiciled in Paraguay, and it falls outside the resolution's scope entirely.

In practice, this means your crypto is held and traded by the foundation. Your name does not appear on exchange accounts. You are not the one "operating" with crypto-assets. The foundation is.

Some commentators have raised the question of whether DNIT could reclassify activity as personal if the resident controls the foreign entity. This is exactly why the specific structure matters. A standard LLC has an identifiable owner. A PIF does not. There is no ownership to look through, which is what makes this structure fundamentally different from simply setting up a foreign company in your own name.

This is consistent with Paraguay's territorial tax system, which does not reach into foreign entities' foreign-sourced activities.

This regulation is brand new and has not yet been tested or enforced. There is no guarantee of any specific outcome. But based on how the resolution is written today, this is the strongest structure available to keep your crypto activity outside the scope of the reporting requirement.

A common question is whether you can actually register and trade on exchanges under a foundation or entity. The answer is yes. Major exchanges like Kraken, Binance, and OKX all support corporate and business accounts.

Some exchanges will accept a foundation directly with its formation documents. Others are set up for more traditional business entities like an LLC in their KYC process.

For that reason, the most practical setup for full exchange access is to have the Panama foundation own a Nevis LLC underneath it.

The LLC handles exchange registration and day-to-day activity, while the foundation remains the owner. This gives you flexibility across virtually all major platforms without complicating how you actually hold or trade. You use the exchange the same way you always have. The only difference is whose name is on the account.

Resolution 47 is the immediate reason many people are looking at this, but the value of this structure goes well beyond one regulation in one country.

Crypto regulations are tightening globally. Countries that were once completely hands-off are introducing reporting frameworks, and in many cases, those frameworks are the precursor to taxation.

Paraguay is following a pattern that has already played out in dozens of other jurisdictions.

Holding your crypto under a properly structured offshore entity protects you regardless of where you live today or where you move tomorrow. Your holdings are not tied to your personal name in any public record. Your assets sit inside a jurisdiction with strong legal protections. And if regulations change in any country, your structure is already in place.

Nevis, for example, has some of the strongest asset protection laws in the world. Creditors must post a $100,000 bond just to initiate proceedings. And there is no public ownership registry. The combination of a Panama foundation with a Nevis LLC is one of the most well-established structures for protecting and holding assets internationally.

For anyone who holds a meaningful amount of crypto, this is the kind of structural planning that makes sense whether or not your country has passed a resolution like this yet.

My partners in Paraguay and Panama and I have been building out this solution since the regulation was announced.

We're handling the full process end to end: foundation formation in Panama & the Nevis LLC, structuring advice, exchange account setup guidance, and ongoing maintenance.

If you're in Paraguay and hold crypto, book a call with me here or write to me here.