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Residency in Paraguay for Brazilians: Mercosur, Investor Pass, and Termination of Brazilian Tax Residency

  • Writer: Camila Hermano
    Camila Hermano
  • 1 day ago
  • 13 min read

A guide to Paraguayan residency for Brazilians, the Paraguay Investor Pass categories, and why the move does not, by itself, end your Brazilian tax residency.

Updated August 2026

If you are considering moving to Paraguay, you have probably already researched the cost of living, taxation, and setting up a company there. What is not always clear is that this move involves three different legal situations: entering Paraguay as a visitor, obtaining migratory residency in Paraguay, and terminating your Brazilian tax residency.

These situations are related, but one does not automatically produce the effects of the other. Holding Paraguayan residency, for example, is not enough for you to stop being a Brazilian tax resident.

In this article, you will learn about the main residency routes available to Brazilians, including the Paraguay Investor Pass, and understand how to coordinate your migratory regularization with the termination of your Brazilian tax residency.

One initial note: although people commonly refer to a “visa for Paraguay,” as a Brazilian you generally do not need a visa before entering the country. If your intention is to settle there, the relevant procedure is obtaining migratory residency.

Entering as a visitor is only the starting point

You can enter Paraguay with a passport or valid national ID, no visa required, and stay in the country for up to 90 days.

Friendship Bridge between Brazil and Paraguay, with both countries' flags

This regime covers tourism trips, family visits, and one-off business activities. Once your intention becomes to reside in Paraguay to work, start a business, study, or retire, you need to apply for the appropriate migratory category with the Dirección Nacional de Migraciones, the DNM.

Overstaying the authorized period without requesting an extension or starting the regularization process can result in fines and other immigration consequences.

The most common route: residency under the Mercosur Agreement

For most Brazilians, the most accessible path is Mercosur Temporary Residency.

The Residency Agreement for Nationals of the Mercosur States Parties and Associated Countries lets you apply for residency in Paraguay mainly on the basis of your nationality, without needing to justify the move in advance through employment, investment, or retirement.

This temporary residency is valid for two years and is not renewable. During that period, you can live in Paraguay legally and exercise the rights recognized by law and by the migratory agreement, including the right to work on equal terms with Paraguayan nationals.

The process is handled by the DNM and requires documents such as identification, certificates, and background checks, subject to the applicable validity, authentication, apostille, and legalization rules. Current legislation no longer requires the former US$ 5,000 bank deposit that used to be a condition for this residency.

The Paraguayan identity card under the Mercosur regime

There is an important peculiarity in the Mercosur route: according to the DNM, if you apply for residency under this agreement, you can only obtain the Cédula de Identidad Paraguaya (the Paraguayan identity card) after reaching permanent residency.

Outside the Mercosur regime, Migration Law No. 6,984/2022 allows, in certain categories, access to the identity card from temporary residency onward. This limitation is therefore a specific feature of the Mercosur process, not a rule that applies to every temporary residency in the Paraguayan system.

Moving to Mercosur permanent residency

If you hold Mercosur temporary residency, you can apply to change to the permanent category.

The application must be filed within the 90 days before your temporary card expires. According to the DNM, if you do not file within that window, you lose the right to process permanent residency through the specific Mercosur Agreement procedure, and need to pursue another migratory pathway.

Once granted, residency is permanent. The migratory card, however, must be renewed every ten years, a deadline that also applies to renewing the identity card itself.

Since July 2026, DNM Resolution No. 407/2026 has unified the criteria for proving economic solvency in permanent residency applications, allowing different ways to demonstrate income, professional activity, or effective availability of resources. In other words, moving to permanent residency does not happen automatically with the mere passage of two years. You need to file the application within the correct window and meet the requirements in force on the filing date.

Foreign participation in Paraguayan companies

Migratory residency and participation in a company are different matters.

You can hold 100% of the shares of an Empresa por Acciones Simplificada (EAS, a simplified stock company) without needing a Paraguayan partner. However, until you hold the Paraguayan identity card, or meet the requirements applicable to managing the company, you may need to appoint a qualified legal representative to carry out certain acts, by power of attorney, subject to Paraguay's rules on registration, legalization, apostille, and translation.

Opening a company in Paraguay, therefore, does not necessarily require you to use the special investor residency. You can, for example, follow the Mercosur migratory route and handle the company's incorporation separately. If your Paraguayan company is part of a broader corporate structure, involving foreign capital or cross-border operations, this is the kind of legal structuring that typically calls for specialized advisory on global expansion and investments.

Permanent residency for investors: the CIE and the Paraguay Investor Pass

In April 2026, Paraguay's Ministry of Industry and Commerce, together with the DNM, significantly updated the regime for issuing the Constancia de Inversionista Extranjero, the CIE (Foreign Investor Certificate).

MIC Resolution No. 0283/2026, signed on 21 April 2026, established a new framework for the procedure, now marketed by the government as the Paraguay Investor Pass. The CIE lets you apply directly for permanent residency, without first needing to obtain temporary residency. The new regime recognizes four investment categories.

Productive investment

Traditionally linked to opening or developing an industrial, commercial, or services activity, this category requires a minimum investment of US$ 70,000, or the equivalent in guaraníes, the creation of at least five direct formal jobs, submission of a business plan, and execution of the investment and hiring within the currently applicable deadline of up to 24 months, along with proof of the origin and availability of the funds.

Real estate investment

Requires a minimum investment of US$ 200,000. The property must be allocated to an economic activity: buying a house exclusively for personal or family use does not, by itself, qualify you for this category. According to the official announcement, there is no requirement to create jobs or submit a business plan under this category.

Financial instruments

Requires a minimum investment of US$ 200,000 in instruments traded on the Paraguayan securities market, held for at least two years. There is no requirement to directly create jobs or manage your own venture.

Tourism investment

Requires a minimum investment of US$ 150,000, allocated to the development of the tourism sector. You need to submit a business plan and remain subject to the technical monitoring set out in the regulation.

Under all four categories, you need to prove economic and financial capacity, submit a statement on the origin of the funds, and comply with immigration and anti-money-laundering controls. The personal documentation usually includes a valid ID, proof of regular entry or stay in Paraguay, apostilled or legalized background checks, an Interpol certificate, documents proving the origin and availability of the investment, and the business plan, when required.

Compliance with the investment remains subject to monitoring: if you fail to meet the commitments made, the Ministry of Industry and Commerce may report the situation to the immigration authority, with possible consequences for the residency granted. The criteria for maintaining residency and the effects of extended periods outside Paraguay should be confirmed directly with the DNM. It is worth reinforcing: being granted permanent residency should not be confused with automatically acquiring Paraguayan tax residency, which follows the country's own tax rules.

Opening a company does not require a US$ 70,000 investment

The US$ 70,000 investment and the creation of five jobs are requirements of the Investor Pass's productive category. They are not general requirements for you, if you simply want to open or hold an interest in a company in Paraguay.

The EAS, for instance, has no general minimum capital requirement. The stated capital should be consistent with the company's activity and operational needs, but does not need to reach US$ 70,000.

You therefore need to weigh two decisions separately: which corporate structure to use for the economic activity, and which migratory category to choose to reside in Paraguay.

Comparison of the main routes

Category

Duration

Minimum investment

Main feature

Mercosur Temporary Residency

Two years

No investment required

First stage of the Mercosur route

Mercosur Permanent Residency

Permanent

No predetermined minimum, but solvency must be proven

Obtained after temporary residency

Investor Pass — productive

Permanent

US$ 70,000

Five jobs and a business plan

Investor Pass — real estate

Permanent

US$ 200,000

Property allocated to economic activity

Investor Pass — financial

Permanent

US$ 200,000

Investment held for two years

Investor Pass — tourism

Permanent

US$ 150,000

Business plan and technical monitoring


For many Brazilians, Mercosur residency remains the simplest alternative, because it does not require a predetermined minimum investment. The Investor Pass categories can be more suitable once you already have an investment project consistent with the amounts and commitments involved.

Migratory residency and tax residency are not the same thing

The residency Paraguay grants you determines your migratory status in that country. Your Brazilian tax residency, in turn, determines how the Receita Federal will treat your income. One does not automatically replace the other.

Imagine you have already obtained Mercosur Temporary Residency and actually moved to Asunción. Migratorily, you already reside in Paraguay. For Brazilian tax purposes, however, it is necessary to check whether you departed on a permanent basis, complied with the corresponding obligations, or completed the legal absence period.

While you remain a Brazilian tax resident, you are, as a rule, subject to Brazilian taxation on your worldwide income, including income earned in Paraguay or elsewhere. Once you acquire non-resident status, Brazil stops taxing your worldwide income and, as a rule, taxes only the income that continues to have a Brazilian source, under the regime applicable to non-residents.

It is also possible for you to become a non-resident for Brazilian tax purposes without holding permanent Paraguayan residency. Temporary residency in Paraguay may exist at that point, but even that is not a requirement for changing your Brazilian tax status: Brazilian law applies its own criteria.

Is there a risk of taxation in both countries?

Brazil and Paraguay signed, on 20 September 2000, a Convention to Avoid Double Taxation on Income Tax, Prevent and Combat Tax Evasion, and Address Customs Matters.

Brazil's Congress approved the text through Legislative Decree No. 972/2003. However, parliamentary approval alone is not enough for a treaty to produce all its effects. According to the official record of Brazil's Ministry of Foreign Affairs in the Concordia treaty database, no promulgation decree or international entry-into-force date is on file. Paraguay also does not appear on the Receita Federal's published list of countries with double-taxation agreements in force.

You should not, therefore, treat the Brazil-Paraguay Convention as an agreement in force for tax-planning purposes.

The absence of a treaty does not mean that all income will necessarily be taxed twice. Whether it is depends on your tax residency, the source of the income, and each country's domestic rules. While you remain a Brazilian tax resident, Paraguayan-source income may be included in your Brazilian taxable base under the worldwide-income rule, and may also be taxed in Paraguay if considered Paraguayan-source. After the termination of your Brazilian tax residency, Brazilian-source income remains subject to Brazilian taxation; whether double taxation occurs will depend on whether that same income is also considered taxable in Paraguay, according to its nature and Paraguay's source rules.

Territoriality of Paraguayan taxation

Paraguay's tax system, governed by Law No. 6,380/2019, on the Modernization and Simplification of the National Tax System, predominantly follows the territoriality principle for individuals: broadly speaking, the Personal Income Tax reaches income considered to be Paraguayan-source, taking into account where the activity is carried out, where the asset is located, the country in which a right is economically used, and the specific rules for each type of income.

For that reason, your foreign-source income is not, as a rule, taxed in Paraguay merely because you reside in the country. Determining the source, however, needs to be done according to the nature of the income and Paraguayan law.

In the absence of a treaty, Brazilian law allows, in certain situations, crediting tax paid abroad when there is reciprocity of treatment. This possibility should not be assumed by you, and needs to be assessed individually, with evidence of the legal requirements.

How to formalize the termination of your Brazilian tax residency

If you leave Brazil on a permanent basis, you need to fulfill two distinct obligations with the Receita Federal: the Communication of Definitive Departure (in Portuguese, Comunicação de Saída Definitiva do País, or CSDP), and the Declaration of Definitive Departure (Declaração de Saída Definitiva do País, or DSDP).

The Communication must be filed between the date of your departure and the last day of February of the following calendar year. The Declaration must be filed the following year, within the deadline applicable to the annual income tax return, and covers the income, assets, rights, and liabilities relating to the period in which you remained a Brazilian resident in the year of departure. Filing the Communication does not exempt you from filing the Declaration.

On a permanent departure, your non-resident status takes effect as of the date of departure, subject to Brazilian rules and compliance with the corresponding obligations. You also need to notify your non-resident status to Brazilian income-paying sources, such as banks, brokerages and financial institutions, companies, tenants, property managers, and other entities that pay Brazilian-source income — including any director's or officer's remuneration you receive from a Brazilian company — so that they update their records and apply the tax treatment specific to non-residents.

What if the departure is not formalized?

If you leave Brazil on a temporary basis, you remain a tax resident during the first 12 consecutive months of absence. Starting the day after you complete 12 consecutive months outside the country, you become a non-resident, according to the Receita Federal's criteria.

The law also sets out obligations for those who leave permanently. For that reason, passively waiting out the 12 months should not be treated as an adequate substitute for the Communication and Declaration of Definitive Departure. Besides leaving formal matters pending, failing to notify income-paying sources can result in banks, companies, and other institutions continuing to incorrectly apply the tax regime meant for residents.

The 90-day myth and the 183-day rule

Normative Instruction SRF No. 208/2002 does not set a general number of days per year that you, as a Brazilian non-resident, can spend in Brazil without reacquiring tax residency. The 90-day or 183-day limits often mentioned in advisory content are not, for Brazilians, a general rule under this regulation.

The 183/184-day count applies to a different situation: that of people entering Brazil on a temporary visa. In that case, the person becomes a tax resident on the date they complete 184 days of presence, consecutive or not, within a period of up to 12 months. This rule should not be applied automatically to you, because you do not enter your own country on a visa.

If you have already become a non-resident and are considering returning, the criterion the law actually sets is different: if you return to Brazil with definitive intent to live there again, you reacquire tax residency as of the date of arrival. A temporary visit does not necessarily amount to a definitive return, but the law does not set, for you, a fixed number of days that, by itself, guarantees maintaining non-resident status. Advisory recommendations suggesting a specific number of days for visits are precautionary measures, not rules set out in law.

When the paperwork does not match the facts

Filing the Communication and Declaration of Definitive Departure is essential, but the documentation needs to be consistent with the reality of your move.

In actual cases, the Receita Federal can question whether a departure was genuine, and the Conselho Administrativo de Recursos Fiscais, or CARF (Brazil's federal tax appeals board), can uphold a tax assessment when the facts as a whole are inconsistent with the claimed non-resident status. A relevant precedent is Case No. 10945.721380/2016-89, which resulted in CARF Decision (Acórdão) No. 2201-011.434, decided on 8 February 2024. In that case, the taxpayer claimed to have moved their residence to Paraguay. The panel weighed various elements tied to connections maintained in Brazil, including electoral domicile, banking activity, and property acquisitions, and upheld the tax assessment and the penalty.

This precedent should be read with caution. Keeping a bank account, property, investment, corporate interest, or family tie in Brazil does not, by itself, prevent you from being a non-resident. How much weight these elements carry depends on the full set of facts and evidence in each case.

Caution is also warranted with the concept of “center of vital interests,” mentioned in commentary on this decision. That concept is characteristic of the tie-breaker clauses in double-taxation treaties, and, as you have seen, the Brazil-Paraguay Convention is not in force. The practical guidance remains the same: your departure paperwork needs to be consistent with the life you actually build abroad, with the nature of the activities you carry out, and with how you treat the income and assets you keep in Brazil.

Important correction about the Brazil-Paraguay treaty

Some content attributes the promulgation of the Brazil-Paraguay Convention to Decree No. 4,852/2003. That reference is incorrect: Decree No. 4,852/2003 promulgates the double-taxation convention between Brazil and Chile, not the instrument signed with Paraguay. The Brazil-Paraguay Convention was internally approved through Legislative Decree No. 972/2003, but, according to the record in the Concordia treaty database (Agreement No. 4668) and the Receita Federal's list of agreements in force (gov.br/receitafederal, updated 9 July 2026), it is not on record as an international treaty in force.


Paraguayan naturalization

After three years of permanent residency, counted from the resolution that granted permanent admission, you may initiate an application for a Letter of Naturalization, regardless of whether you reached it through the Mercosur route or through investment.

The mere passage of that period does not by itself grant automatic citizenship. The Paraguayan Constitution also requires legal age, regular exercise of a profession, trade, science, art, or industry, good conduct, and compliance with the documentary and procedural requirements set by the Paraguayan Judiciary. Naturalization is a separate procedure, and should not be confused with obtaining permanent residency or the Paraguayan identity card.

In summary: Paraguay residency for Brazilians

For most Brazilians, Mercosur residency remains the most accessible migratory route: you first obtain two-year temporary residency and, within the correct window, apply for permanent residency, meeting the requirements in force.

The Paraguay Investor Pass offers direct access to permanent residency through four categories — productive, real estate, financial instruments, and tourism — each with its own amounts, documents, and commitments.

None of these residencies, however, automatically ends your Brazilian tax residency. You need to handle the termination of your tax residency separately, through the Communication and Declaration of Definitive Departure, updating your income-paying sources, and correctly treating the income and assets you keep in the country. Since there is no double-taxation agreement in force between Brazil and Paraguay, your planning needs to carefully take into account both countries' domestic laws.

More than gathering paperwork, your move needs to show consistency between your migratory status, your tax residency, your economic activity, and the actual facts of your life.

Since migratory and tax rules can change, and did in fact change throughout 2025 and 2026, always confirm the requirements in force with official sources before filing any application or making any investment.

Official sources

Dirección Nacional de Migraciones of Paraguay (migraciones.gov.py); Mercosur Temporary Residency and Mercosur Permanent Residency (migraciones.gov.py); Permanent residency for investors (migraciones.gov.py); Paraguay Investor Pass (mic.gov.py); Frequently Asked Questions on the EAS (suace.gov.py); Paraguayan Migration Law No. 6,984/2022; Paraguayan Law No. 6,380/2019, on income taxation; Receita Federal, Resident and Non-Resident and Declaration of Definitive Departure (gov.br/receitafederal); Receita Federal, Agreements to avoid double taxation (gov.br/receitafederal); Normative Instruction SRF No. 208/2002; Normative Instruction RFB No. 1,500/2014; CARF Decision No. 2201-011.434, Case No. 10945.721380/2016-89; Brazil's Ministry of Foreign Affairs, Concordia treaty database, Agreement No. 4668; Paraguayan Judiciary, Letter of Naturalization (pj.gov.py).

Informational content, updated August 2026. Each person's migratory, corporate, and tax situation may require individualized professional analysis.

About the author

Camila Hermano is a lawyer with more than 25 years of experience in corporate and international law. She holds a master's degree in International Law, Investment, Trade and Arbitration from Heidelberg University, in Germany, and from Universidad de Chile, and advises Brazilian and foreign companies on internationalization, foreign trade, foreign investment, and international contracts.

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