The first substantial legal pushback against Paraguay's crypto reporting regime arrived on 18 August 2026, when criminal lawyer and compliance specialist Eduardo Hillar set out three objections to General Resolution 47/2026 in ABC Color. His central claim is narrow and awkward for the tax authority: the DNIT has to justify why it needs each individual field it is demanding.
The Three Objections to Resolution 47/2026
The first is constitutional. Article 179 of Paraguay's constitution reserves the creation of tributes to a formal law of Congress. Resolution 47/2026 is an administrative act of the DNIT, and on Hillar's reading an administrative act cannot carry an obligation of this weight on its own.
The second concerns data protection, and it is the argument with the most teeth. Paraguay passed Ley 7593/2025, its personal data protection law, which imposes minimization, purpose limitation and retention limits. Hillar points to Articles 4, 5, 14, 15, 20 and 27 and argues that collecting a full transaction ledger, field by field, without justifying each element against a stated purpose, is what that law exists to prevent.
The third is practical. The resolution asks for the identification of the parties to an operation. In decentralized finance there frequently are none in the sense the form means, because a smart contract executes the transaction rather than a counterparty who can be named.
What the Crypto Declaration Actually Asks For
The detail is what makes the argument concrete. For each reportable operation the return calls for the date and time, the identification of the parties, the public wallet addresses, the cryptoasset and its network, the quantity to ten decimal places, the gross value in dollars, commissions and gas fees, the transaction hash, and the origin and destination addresses.
There is no minimum size for an individual operation once you are in scope. Scope is set elsewhere: the declaration reaches residents and entities in Paraguay whose crypto operations pass US$5,000 in a year, along with platform operators. We set out the mechanics when the detail first emerged, in the data DNIT will collect.
Two of Hillar's lines frame the risk better than a summary can. On linking wallets to identities: "once exposed, this cannot be cancelled or replaced", which turns the resulting database into what he calls a high-value target. And on the underlying inconsistency: the state says crypto is not money, then asks for the traceability it would demand of money.
What Happens Next, and What Does Not
Nothing about the obligation has changed. The first declaration still covers fiscal year 2026 and is still due in March 2027 through Marangatú, and it still has to be registered in your RUC under code 959-DJI Criptoactivos. An argument in a newspaper is not a court ruling.
What has changed is that a specific, citable case now exists, which matters if the rule is ever challenged formally. Constitutional objections to tax rules made by resolution rather than by law are not exotic in the region, and they occasionally succeed. The wider direction of travel, from CRS information exchange to the reporting rules themselves, has been one way for several years.
What Crypto Holders in Paraguay Should Do Now
The practical advice does not change, and the objection arguably strengthens it. Keep your 2026 records as though the declaration will be filed exactly as written, because the safest assumption is that it will be. Reconstructing a year of wallet activity from memory in March 2027 is the expensive way to do this.
Two things get conflated and should not be. This is a reporting obligation, not a new tax. Paraguay's territorial system still leaves foreign-source income outside the local net, and a declaration listing your transactions does not by itself create a liability on them. What it removes is the practical obscurity some holders were relying on.
If the challenge ever lands, it would most plausibly narrow the fields rather than remove the regime. Planning around the wide version and being pleasantly surprised is the cheaper mistake.
US citizens and green-card holders: none of this changes your position. The United States taxes worldwide income on the basis of citizenship, so your crypto gains are reportable there regardless of what Paraguay does or does not collect.
Frequently Asked Questions About the Paraguay Crypto Rule
Does the legal challenge suspend the crypto reporting obligation?
No. Resolution 47/2026 remains in force, and the first declaration still covers 2026 and is still due in March 2027. The objections were raised publicly by a lawyer, not by a court, and no suspension has been granted.
Why does Article 179 matter for a tax resolution?
Because it reserves the creation of tributes to a law passed by Congress. The argument is that an administrative resolution cannot impose an obligation of this scope on its own. Whether a reporting duty counts as a tribute for that purpose is exactly the point in dispute.
Does Paraguay tax my crypto gains?
Not when they are foreign-source and you are resident under the territorial system. The declaration is informative, so it makes activity visible without automatically making it taxable. Local-source gains are a different matter and worth advice.
Unsure whether your crypto sits inside or outside the Paraguayan net? A first conversation is free and starts with where the income actually arises rather than where the wallet is. Get in touch.
Disclaimer: This article is general information, not legal or tax advice, and it reports one lawyer's arguments rather than a settled legal position. Confirm your own obligations with the DNIT or a qualified Paraguayan adviser before acting on them.
Sources
About the author
Yannick Schroth
Founder · Paraguay relocation advisor
Lives in Asunción and guides international nomads, entrepreneurs and investors toward residency, a cédula and a tax-efficient structure in Paraguay.
