Paraguay land of opportunities

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“Land of Opportunities” PARAGUAY パラグアイ共和国 チャンスに満ちた国

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Brochure | Investment

Transcript of Paraguay land of opportunities

Page 1: Paraguay land of opportunities

“Land of Opportunities”PARAGUAY

パラグアイ共和国「チャンスに満ちた国」

Page 2: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 3: Paraguay land of opportunities

Message from the Ambassador

Located at the heart of the South American continent, Paraguay’s outstanding and consistent economic growth in recent times has attracted the attention of investors and business, not only from the surrounding countries, but also from the entire world. Paraguay has experienced a solid average economic growth of 5.1 % annually in the past 10 years up to 2015, achieved mainly by the production of more than eight million tons of soybean (fourth largest exporter in the world), and a record export of high quality beef (sixth largest exporter in the world).

Moreover, Paraguay has an open and very attractive policy for the foreign investments, i.e., tax incentives such as the 60/90 and Maquila Laws, and the recently enacted Law of Investment Guarantee 5542/15.

On the other hand, Paraguay has abundant and low cost clean energy, young and trainable labor force, and o�ers a �nancial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Also, industrial parks o�er excellent opportunities for foreign industries to settle in Paraguay with good transportation access routes and basic facilities such as electricity, running water, and high speed internet already in place.

 南米の中心部に位置するパラグアイは近年堅実な急成長を遂げており、近隣国ばかりでなく、世界各国の投資家、産業界から注目を集めております。

 パラグアイは2015年迄の過去10年間に平均年率5.1%のGDP成長をしてきました。これは主に世界第4位の輸出を誇る大豆生産と、同じく世界第6位の輸出量に位する高品質の牛肉の生産に依るものであります。

 その上、パラグアイは外国からの投資に対して、60/90法やマキラ法のような免税や昨年立法化された投資保証法5542/15によるオープンで魅力ある政策を進めております。

 一方、パラグアイには豊富で安価なクリーンエネルギー、若く訓練可能な労働力があり、健全財政及び着実に改善されている信用格付けと資本の自由な移動に支えられる金融制度を提供しています。

1

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

大使の挨拶

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

From Japan, induced by the above mentioned favorable conditions, one important shipbuilding company, and three well known auto-parts industries have already installed their manufacturing plants in Paraguay.

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$ 75 billion in infrastructure works, which is remarkable considering that the above public wok investment during the past 12 years was below US$ 180 million per year.

Lastly, I am very pleased to publish the second edition of this small publication, which I hope aids you in reviewing and concluding like many others, that Paraguay is a true land of opportunities for your endeavors.

Naoyuki ToyotoshiAmbassador of the Republic of Paraguay

May 2016

 また、便利な交通アクセス、電気、水道、高速インターネットを備えた工業団地を提供して、外国からの工業に定着のための便宜を図っております。

 日本からも、上記の好条件に誘発されて有力な造船会社が一社、よく知られた自動車部品企業3社が既に進出しております。

 パラグアイ政府は2015年から2018年の間に750億ドルのインフラ投資を計画しております。このプロジェクトは過去12年間の平均年間公共投資が1億8千万ドルであったことを考慮すると注目に値します。

 最後に、この小誌の第2版を出版されますこと大変嬉しく存じますとともに、皆様がパラグアイを見直されて、パラグアイが「チャンスに満ちた国」であることを納得されるための一助になりますことを祈念します。

駐日パラグアイ共和国大使館特命全権大使

トヨトシ ナオユキ2016年5月

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 4: Paraguay land of opportunities

Paraguay Area (km²)

406,752

O�cial Languages

Spanish and Guarani

Currency

Guarani (since 1943)

Population (2015)

6,755,756

Nominal Gross Domestic Product (GDP)Year 2015

US$ 27.7 billion

Nominal Gross Domestic Product (GDP Per Capita)Year 2015

US$ 3,957

Capital

Asuncion

Other cities and major economic areas

Ciudad del Este, Encarnacion, Salto del Guaira, Coronel Oviedo, Concepcion, Santa Rita

Economically Active Population – EAP (2014)

4,100,855 61.6% of population

Rate of unemployment (2014)

6.4% of the EAP

The Republic of Paraguay, located in the heart of South America, o�ers a unique set of opportuni-ties for investors who are trying to obtain the best cost-benefit investment. Paraguay provides not only abundant and low cost natural energy and labor resources, but also a strategic location that enables access to the most important markets with the highest income in the region. All this is o�ered in a national legal framework that welcomes foreign investment in a positive and stable economic environment.

2

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

パラグアイ共和国は南米の中心部に位置し、ビジネスにおいて最善のコスト-ベネフィット(費用対効果)の割合を追及する投資家にとって、他に追随を許さないほどチャンスを見出せる国である。パラグアイは単に豊富なクリーンエネルギーや安価な労働力を提供するのみならず、地域内で最も収入の高い重要な市場への進出に対して戦略的な位置を占めている。パラグアイは外国投資に開放された法的枠組と、安定し前向きな展望に恵まれる経済環境の下で上記のあらゆる利点を提供できる。

パラグアイ

面積 (km²)

公用語

通貨

人口 (2015年)

首都

その他主要都市

労働力人口‒ EAP (2014年):

失業率(2014年)

人口の61.6%

労働力人口の6.4%

GDP 2015年

スペイン語、グアラニー語

アスンシオン

グアラニー (1943年から)

(US$ 100万単位) US$ 27,700

一人当たりのGDP 2015年

US$ 3,957

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 5: Paraguay land of opportunities

The friendly relationship between Japan and Paraguay has also been strength-ened by the O�cial Development Assis-tance (ODA) provided by the Government of Japan to the Government of Paraguay since 1959. This assistance, mainly implemented through the Japan Interna-tional Cooperation Agency (JICA), consists of the provision of technical cooperation, non-reimbursable financial cooperation and loan assistance. Up to March 2012, Japan’s total ODA to Paraguay reached approximately JPY 250,000 million to support the development of the agricul-ture, infrastructure, health and education sectors.

• In April 1936 the Paraguayan Government granted its consent to 124 families of Japanese immigrants to enter the country.

• This first group settled in an area of approximately 11,000 hectares on a plateau located about 130 km southeast of Asuncion, establishing the colony of “La Colmena” to engage in agricultural activities.

• In 1959, the Governments of Japan and Paraguay signed an Immigration Agreement which approved the immigration of 85,000 Japanese in a 30-year span.

日本とパラグアイ間の友好関係は、1959年以来日本政府がパラグアイ政府に提供してきたODAによる援助によって強化されて来た。この支援は日本の国際協力機関(JICA)を中心として実行されてたものであり、その柱となるのは技術協力、無償資金援助、開発用資金の借款である。

日本による対パラグアイのODA総額は2012年3月時点で農業開発、インフラ、医療、教育部門を中心に2,500億円に達している。

3

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• In 1960, the Japan International Cooperation Agency (JICA), acquired land in what is today the district of Pirapo in Itapua, where 26 Japanese families settled, and 87,000 hectares in Alto Parana to establish the Colonia Yguazu, currently the largest colony of Japanese immigrants in the country.

• The Japanese introduced soy to Paraguay. The first large scale productions started in the Japanese colonies in Itapua.

• 1936年4月、パラグアイ政府は124家族の日本人移民受け入れに合意した。

• この日本人移民第1陣は首都アスンシオンの南東約130kmに位置する約11000ヘクタールの面積の台地、「ラ・コルメナ」入植地に定住して農業に従事することになった。

• 1959年、日本とパラグアイ政府間で移民協定が署名された。これを契機として以降30年間に、85000人の日本人移民の入国が認められた。

• 1960年、国際協力事業団(JICA)はイタプアのピラポ地域の土地買収を行い、日本人26家族が入植した。更に、アルト・パラナのコロニア・イグアスの土地87.000ヘクタールを購入し、この地は現在、最大の日本人移民入植地となっている。

• パラグアイに大豆を持ち込んだのはこの日本人移民であった。最初に大規模生産が開始されたのは主としてイタプアの日本人入植地であった。

Handshake designed by Pavel Pavlov from the thenounproject.com

Paraguay and Japan: A long-standing friendly relationship

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

パラグアイと日本:長年の友好関係Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

2016: 80th Anniversary of Japanese Immigration to Paraguay2016: パラグアイ日本人移住80周年

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 6: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

A. 南米の主要市場へのアクセスB. 競争力ある資源C. マクロ経済の安定性と金融の自由D. 各種インセンティブと有利な税制度E. 外国投資の保護と良好なビジネス環境

Paraguay, a land of opportunities o�ers you:A. ACCESS TO THE BIGGEST MARKETS IN SOUTH AMERICAB. COMPETITIVE RESOURCESC. MACROECONOMIC STABILITY AND FINANCIAL FREEDOMD. BENEFICIAL TAX SCHEME AND INCENTIVESE. FOREIGN INVESTMENT PROTECTION AND GOOD BUSINESS ENVIRONMENT

4

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

パラグアイ、チャンスに満ちた国は以下を提供する:

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 7: Paraguay land of opportunities

Argentina

Bolivia

Peru

Ecuador

Colombia

Venezuela Guyana

Surinam

French Guiana

Uruguay

Brazil

パラグアイは、メルスコル(南米共同市場)の加盟国であり、3億人を超える人口を擁する市場への自由なアクセスが可能である。又、戦略的位置を占めることから、ブエノスアイレス、サンパウロ、モンテビデオ、サンチャゴ等の各国首都からそれぞれ飛行機で2時間という至近距離にある。更に、現在建設中の両太洋回廊の中心に位置することから、地域内の主要な港や市場、及び、太平洋、大西洋両岸に所在するフリーポートへのアクセスも容易である。

5

Paraguay River

Parana River

Tiete River

Parana River

Uruguay River

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

1,300km

Paraguay

Tiete-Parana

2,400km

AN IMPORTANT WATERWAY IN THE REGION

Paraguay - Parana - Uruguay

2,770km

Main Commercial

Centers重要市場

河川船海上船

パラグアイの自由港

地域の重要な港

Paraguayanfree ports

Barges Transatlantic Ships

Importantregional ports

Santiago

Buenos Aires Montevideo

Sao Paulo

ASU

Santacruz

Antofagasta

RosarioNueva Palmira

Paranagua

Mejillones

SantosCDE

Conchas

Corumba

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

南米の大河が国を流れる

(全長)

(全長)

Source: 2012 Latin American Statistic Yearbook - ECLAC www.eclac.org *Projection Yr. 2013 **In current US$ (2011)

ACCESS TO ATTRACTIVE MARKETS

Paraguay is located in the center of the regionwith the highest income of South America

Population (Million)

Nominal GDP* (US$ Billion)

Average GDP per Capita** (US$)

South America(100%)

South America(100%)

South America(100%)

MERCOSUR(70%)

MERCOSUR(70%)

MERCOSUR(70%)

405

4,539

7,946

281

3,311

10,402

パラグアイは他の高所得地域に隣接し、南米大陸の中央に位置する

人口(百万人)

名目GDP(US$ 十億)

一人あたりのGDP平均(US$)

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

A) A

CC

ESS

TO TH

E BIG

GES

T MA

RK

ETS IN

SO

UTH

AM

ERIC

A

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

南米の重要市場へのアクセス

A) ACCESS TO THE BIGGEST MARKETS IN SOUTH AMERICA

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 8: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

LOGISTIC NETWORK 物流ネットワーク

陸路

既存鉄道

計画中の鉄道

道路

ASU

Belo Horizonte

BrasiliaCuiaba

Santacruz

La Paz

Antofagasta

Santiago

Buenos Aires

MontevideoN. Palmira

Rosario

Cordoba

Salta

Jujuy

Resistencia

Santa Fe

CampoGrande

Punta Pora

PJCRio de Janeiro

Santos

Paranagua

Curitiba

Curitiba (PR)Sao Paulo (SP)Rio de Janeiro (RJ)Buenos Aires (AR)Montevideo (UY)Santiago (CL)Santa Cruz (BO)

Roads from Asuncion (PY)

965 km

1,370 km

1,485 km

1,269 km

1,400 km

2,250 km

1,300 km

Porto Alegre

Current Railways

Projected Railways

Road Network

Rio Grande

Sao Paulo

CDE

ENCENC

Source: IIRSA - www.iirsa.org

6

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

A) A

CC

ESS

TO

TH

E B

IGG

EST

MA

RK

ETS

IN S

OU

TH A

MER

ICA

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

パラグアイ輸出産物の殆どは、パラグアイ-パラナ川を経由して、ブエノスアイレス、モンテビデオ、ロサリオの各港に河川を航行して運搬される。又、アスンシオンからの国内ルートは、エンカルナシオンやシウダー・デル・エステといった国境沿いの都市と結ばれており、ブラジル・アルゼンチンへの輸送も容易である。

パラグアイはメルコスル(加盟国はアルゼンチン、ブラジル、ウルグアイ、及び、ベネズエラ)の創設以来の完全加盟国であり、加盟国に対して関税フリーで輸出が可能であり、又、太平洋同盟の公式オブザーバー国であり、将来の加盟国候補でもある。

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 9: Paraguay land of opportunities

更に2014年以降、パラグアイはメルスコル加盟国の中でEUによるGSPプラス(一般特恵関税システム)の唯一の適用国である。パラグアイは同時に、1995年の設立時からWTOに加盟しており、現在に至るまで提訴等の紛争当事国になった事は一切無い。

• 若く、訓練可能な労働力:パラグアイは南米で最も若い人口を有しており、総人口の73.7%が34歳以下で構成されている。労働力コストはメルスコル域内でも最も競争力が高い。

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

7

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

“Paraguayan labor o�ers high and satisfactory performance worldwide within our company”

(Ignacio Ibarra – CEO FUJIKURA)

YOUNG AND TRAINABLE LABOR FORCEPopulation younger than 34 years old (%) 34歳以下の人口 (%)

Paraguay Bolivia LAC Average Brazil Chile Argentina Uruguay

Sources: Dirección Nacional de Estadísticas, Encuestas y Censos (www.dgeec.gov.py) Worldmapper (www.worldmapper.net) / http://www.abc.com.py/edicion-impresa/economia/paraguay-opcion-de-futuro-para-empresas-brasilenas-558514.html

73.7 73.467.4 65.7

60.1 59.954.8

Paraguay has the youngest population in Latin America.

我が社の世界基準で、パラグアイの労働者は満足すべき良好な効率をあげています。

イグナシオ・イバラ フジクラ社CEO

最低賃金: 330米ドル社会保障: 16.5% (55米ドル)計: 385米ドル

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

Minimum Wage: US$330 Social Benefits: 16.5% (US$55) Total = US$385

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

B) C

OM

PETITIVE R

ESO

UR

CES

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

B) COMPETITIVE RESOURCES

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

競争力ある資源

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 10: Paraguay land of opportunities

50 MWh

month

• クリーンで安価なエネルギー:パラグアイはメルコスル域内で最大の発電量を擁し、又、電力コストにおいて最も競争力ある国々の一角をなす。従って、電力集約産業は、技術開発にとって必要な最良のインフラを手にする事ができる。パラグアイはイタイプ、ヤシレタ、アカライという3つの水力発電用ダムを持つ最大の電力輸出国であり、今後、その数を更に増大させる潜在能力を有する。イタイプはパラグアイとブラジル国境に位置する2国間企業である。同水力発電所は14,000メガワットの発電能力を有し、毎時9万ギガワットに及ぶ最大発電量を誇る。パラグアイは非常に安価な電力を生産しているが、発電量の約13%を国内で消費するにすぎない。イタイプの発電量に加え、アルゼンチンと共同で建設したヤシレタ発電所によって、パラグアイは100%再生可能であり、「温室効果」を産み出す二酸化炭素ガスを排出しない電力の世界最大の輸出国となっている。

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

8

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

CLEAN ELECTRIC ENERGY AT LOW COSTCost of Electricity for Industries 50 MWh/month in US$

Paraguay

Peru

Chile

Brazil

Mexico

Colombia

Uruguay

Guatemala

El Salvador

Dominican Rep.

Costa Rica

US$ 59

US$ 82

US$ 107

US$ 121

US$ 135

US$ 139

US$ 151

US$ 195

US$ 218

US$ 233

US$ 246

エネルギー価格・工業部門  50 MWh/月当たりUS$

パラグアイ

ペルー

チリ

ブラジル

メキシコ

コロンビア

ウルグアイ

グァテマラ

エルサルバドル

ドミニカ共和国

コスタリカ

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

Source: CIER Energy Report on CIER Countries 2013

B) C

OM

PET

ITIV

E R

ESO

UR

CES

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 11: Paraguay land of opportunities

• 土地:不動産価格も非常に安価である。過去10年間、コンサルタント会社であるマーサーヒューマン・リソース・コンサルティング社の発表によれば、アスンシオン市は5回連続で、世界で最も物価の安い首都であるとされている。

• 域内で最も低い税率:パラグアイは域内で最も税率の低い税制度を有し、国内で生産に従事する企業は最も安い生産コストを享受することが可能となる。

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

9

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

COMPETITIVE TAX SYSTEM

TAXES

CORPORATE INCOME TAX

PERSONAL INCOME TAX

VALUE ADDED TAX (VAT)

PARAGUAY

10%

10%

10%

35%

35%

21%

25%

25%

23%

34%

27.5%

25%

ARGENTINA URUGUAY BRAZIL

Plug-In designed by Edward Boatman, Lightning designed by Ryan Oksenhorn, Tree designed by Humberto Pornaro, Tax designed by Juan Pablo Bravo from the thenounproject.com

税の種類 パラグアイ アルゼンチン ウルグアイ ブラジル

法人税

個人所得税

 付加価値税

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

Source: Ministry of Finance (www.hacienda.gov.py)

B) C

OM

PETITIVE R

ESO

UR

CES

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 12: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

パラグアイ経済成長率 1996-2015

経済成長率(%)

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

STRONG ECONOMIC GROWTH FOR A DECADE…

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

10

C) M

AC

RO

ECO

NO

MIC

STA

BIL

ITY

AN

D F

INA

NC

IAL

FREE

DO

M

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

Paraguay economic growth 1996-2015

Econ

omic

Gro

wth

(%)

1.6

4.2Average平均成長率1996-2005

1.19

Average 平均成長率2006-2015 5.1

0.1 0.0

2.1

4.85.4

6.4

13.1

14.0

4.7

3.0

-1.4-2.3

-0.8

-4.0

-1.2

0

2

-2

4

-4

-6

6

8

10

12

14

Source: IMF-WEO Update Apr-2015 and CBP.

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2015

2014

4.1

GDP

4.34.3

パラグアイは予測可能な経済と、管理可能なインフレ水準に特徴づけられる良好な投資環境を提供する。

過去10年間、パラグアイは平均年率5.1%の堅固な経済成長率を記録した。この数字は域内で最も成長率の高い国の一つであることを示している。2014及び2015年のパラグアイのGDP成長率は4.7%及び3%であった。この数字はメルコスール加盟国で最も成長率の高い国の一つであることを示している。

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

C) MACROECONOMIC STABILITY AND FINANCIAL FREEDOM

マクロ経済の安定性と金融の自由

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 13: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

2006年から2015年の平均経済成長率

米ドル為替交換率 (2008年1月の指数を100とする)

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

C) M

AC

RO

ECO

NO

MIC

STA

BILITY A

ND

FINA

NC

IAL FR

EEDO

M

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

Average economic growth 2006-2015

(%)

Source: The World Bank (GDP growth annual%) 2016

パラグアイは最近70周年を迎えた通貨(グアラニ)の歴史において高いインフレ率を経験したことも無く、また、発行開始以来デノミも行っていない.

Source: Bloomberg  出所:ブルームバーグ

80

130

180

230

260

M02

-08

M05

-08

M08

-08

M11

-08

M02

-09

M05

-09

M08

-09

M11

-09

M02

-10

M05

-10

M08

-10

M11

-10

M02

-11

M05

-11

M08

-11

M11

-11

M02

-12

M05

-12

M08

-12

M11

-12

M02

-13

M05

-13

M08

-13

M11

-13

M02

-14

M05

-14

USD exchange rate (Index January 2008 = 100)

Real

Peso

Guarani

Guarani (Paraguay)

Peso (Argentina)

Real (Brazil)

11

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

グアラニ(パラグアイ)

ペソ(アルゼンチン)

レアル(ブラジル)

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

5.55.0 4.9

4.64.3

3.8 3.7

2.8

1.8

5.1

0

2

4

6

ARGPER URUPAR COLBOL CHI VENECU BRA

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 14: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

パラグアイは健全な資本、信用リスクのコンスタントな改善、自由な資金の移転などの利点を持つ金融システムを提供する。2013年から2014年の間の平均利益と送金額は8億5300万米ドルであった。

パラグアイのROI(投資回収率)は22%とラテンアメリカ諸国では第2位を占めていた。第1位はペルーの25%であった。出所:CEPAL-ラテン・アメリカカリブ経済委員会ー(2014年度地域見通し)

12

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

C) M

AC

RO

ECO

NO

MIC

STA

BIL

ITY

AN

D F

INA

NC

IAL

FREE

DO

M

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

Rating

Ba2 Feb 2014

Jan 2013

Dec 2010

Jun 2010

Apr 2008

Nov 2007

Apr 2003

Oct 1995

+

+

+

Ba3

B1

B3

B3

Caa1

Caa1

BB-(initial)

Credit Watch Date Rating Credit

Watch Date Rating Credit Watch Date

BB Jun 2014

Dec 2013

Aug 2012

Jun 2012

Aug 2011

Aug 2010

Jun 2007

-

+

BB-

BB-

BB-

BB-

B+

BJul 2004B-Feb 2003SDNov 2002B-Jun 1999BFeb 1999B+

Jul 1999B2(initial)

Jan 2014

Ratings up

Ratings down

Initial ratings

BB-

Ba1 Mar 2015 BB Jun 2015 Jan 2015BB

Feb 2013BB-(initial)

Source: Bloomberg

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Standard & Poor’s (BB+), Moody’s (Ba1), and Fitch (BB), all upgraded Paraguay’s credit ratings in the last two years, leaving it one-step and two steps away from investment level respectively.

スタンダード&プアーズ(BB+)、ムーディーズ(Ba1)、フィチ(BB)等パラグアイの信用度を過去2年間でワンランク又はツーランク上げました。

+

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 15: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

パラグアイの税制は簡便であり、投資法は内外投資家への同一の取り扱いを保証している。パラグアイは又、幾つかの国々との間に投資保証協定を締結している。投資法(法令60/1990)マキラ法、フリーゾーン法など多くの優遇措置がある。

13

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

D) B

ENEFIC

IAL TA

X SC

HEM

E AN

D IN

CEN

TIVES

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

各種インセンティブと有利な税制度

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

D) BENEFICIAL TAX SCHEME AND INCENTIVES

Import tari� on Capital Goods (machinery & equipment)

0%

Value Added Tax (VAT) on acquired Capital Goods (in or out of the country)

Taxes on remittances abroad & payments of loans obtained abroad (capital, interest & commissions)

applied to investments over US$5 million

0%

0%Taxes on payment of dividends & transfer of profits abroad (applied for investments over US$5 million for 10 years)

0%

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

I. Law 60/1990 - 1990年発布の法律第60号II. Maquila Regime - マキラ(保税)制度III. Duty-Free Zones - 保税地域(フリーゾーン制度)IV. Industrial Parks - 工業団地V. Exports Incentives - 輸出インセンティブ

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 16: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

I. 1990年発布の法律第60号

1990年発布の法律第60号に準じて、内外投資家は以下に記載される税金の支払いが免除される:

• 投資プロジェクトにおける資本財、原材料、及び投入財の 輸入時の関税及び国内税

• 工業及び農牧畜業の生産施設において使用される資本財 購入の際の付加価値税

• 会社や団体の設立、登記、登録に関わるあらゆる税金

• 元金、利息及び手数料の外国送金や支払い(500万米ドルを 超える投資に適用)に関する税金

• 500万ドル以上の金額で外国からの融資の場合の 元金・利息・及び手数料の外国送金に課する税金

上記の税法上の特典を得ることを希望する投資プロジェクトは商工省及び大蔵省の承認を得る必要がある。

適用の可能性1990年発布の法律第60号により定められる税金支払いの免除は以下の投資に適用される:資金調達、資本財、特定の技術支援、鉱業、ホテル業、資本財のリース、乗客及び貨物の空輸、河川輸送、陸路の一般貨物輸送、乗客の公共輸送、保健医療、ラジオ、テレビ、マスコミ、地方及び市街地の固定電話、移動電話、科学研究、倉庫保管、データ通信サービス等。

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

14

D) B

ENEF

ICIA

L TA

X S

CH

EME

AN

D IN

CEN

TIVE

S

資本財輸入税 (機械・器具)

資本財に対しての付加価値税(国内、国外適応)

海外宛の融資に対する資本金・金利・手数料の送金の税(500万ドル以上の投資に限る)

配当金の支払い、利益の海外送金に対しての税金(10年、500万ドル以上の投資に限る)

0%

0%

0%

0%

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

MAQUILA CONTRACT

COMPANY ABROAD

EXPORTS

MAQUILA OPERATION

PRODUCTS・ GOODS・ SERVICES

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 17: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

II. マキラ(保税)制度

マキラ制度とは、パラグアイに所在する企業が輸出用の財やサービスを生産するシステムである。生産は国際契約を通じて海外の親会社が行い、世界中のすべての国に出荷することができる。本制度の下で財を生産した場合に享受する主な特典は以下の通りである:

• 製造加工やその後の輸出を目的として一時的に輸入する原材料、投入財、部品や構成要素について関税その他の税金支払いの免除

• 同様に、マキラ事業に関連して一時的に輸入される機械設備について、契約に定められる期間、関税その他の税金支払いの免除

• マキラ生産を補完する財やサービスの国内における供給の可能性

• 部分的及び補完的な製造過程における国内企業への下請け契約(準マキラドーラ)に対する税金について、特別取り扱いの可能性

• マキラ契約履行に関連する輸出入、借入金、その他の事業に関わる税金の免除

• マキラ契約により生産された商品の輸出にあたっては、付加価値 又インボイス価格かいずれか高い方に1%の単位課税

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

15

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II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

HEAD COMPANY

TO PRODUCE:・ Tangible goods・ Intangible goods・ ServicesFOR EXPORT

生産のため:・ 有形財 ・ 無形財・ サービス

マキーラ請求書:労働 +財・サービス +減価償却 +マキーラサービス

Temporary import of capital goods,primary materials, elements, parts, components.

仮輸入の資本財・原材料・投入財・部品・コンポーネントの一時的な許可

国内市場最大前年度生産の10%までは適用される関税並びに税金の支払い後(一時的に停止されていた関税/税金の再適用)

その他のメルコスール加盟国に向けて輸出準備が出来た製品及びサービスは、非課税でメルコスール加盟国に持ち込みが可能

MAQUILA INVOICEWORKFORCE COSTS +

GOODS AND SERVICES +DEPRECIATION +

MAQUILA SERVICE

NATIONAL MARKETUp to 10% of previous year’s production can be sold paying applicable taxes or duties(reinstatement of temporarily suspended taxes/duties).

TAX SUSPENSION

SINGLE MAQUILA TAX

with warranty policy presented

1% over the national value added or issued invoice

MAQUILA COMPANY

マキラ事業を実施するには、企業は「マキラ計画」を作成して、輸出マキラドーラ産業国家委員会(CNIME)の承認を得るために提出しなければならない。計画が承認されたマキラドーラ企業は、税関当局が承認するに充分であると認める許容可能な税額に相当する保証を提供するように義務付けられる。同保証は一時的に輸入された産品が海外に輸出される際に清算され、返還される。提供される保証の種類(包括的、又は流動的)によらず、あらゆる種類の税金が免除され、金利も課される事は無い。この保証は、財、産物、又はサービスの一時的なマキラ輸出制度にも通用される。

CONTRACT

Factory designed by Owen Payette McGarry, Building designed by Nate Eul, Box designed by Josh Deane from the thenounproject.com

INTERNATIONAL MARKET

TO OTHER MERCOSUR MEMBER COUNTRIESProducts and services ready for export can enter other Mercosur member countries

free of tax

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

本社 マキラ会社

国際市場

契約

課税停止担保提出によって関税並びに税金が停止

マキーラ税パラグアイでの付加価値かインボイス価格の1%

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 18: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

MERCOSUR “Rules of Origin”

Necessary regional (MERCOSUR) content

Brazil Argentina Uruguay Paraguay

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

Source: Law 523/95 - National Free Zone Council 出所:法律第523号/95

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

16

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S

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

パラグアイは最も競争力ある「原産地ルール」を持ち、60%までの部品は海外調達可能であり、40%のみがメルコスルを原産地としなければならない。このルールに則り、パラグアイ内で生産される物品が免税で域内全体に輸出されることが可能である。

メルコスール原産の規則

必要な地域のコンテンツ

労働力を多く使用する産業は2023年まで特別優遇制度がある。原産地証明は他のメルコスール国と比較し、パラグアイの方が取得しやすい。

60% 60%

50%40%

60%40%

Extra zone imported components allowed in product

Required regional components:・Raw materials・Parts & components・Labor ・Services・Energy, water・Import Freights*

* If the service is provided by a company established in Paraguay

Paraguay has a “special treatment” regarding “rules of origin” of manufactured products until 2023. It is easier for a product to acquire “MERCOSUR origin” in Paraguay than in any other member country.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Free Zone Import

Service Suppliers in Paraguay

0% taxes

0.5%Taxes on invoice value

Service Suppliersinside FZ

Clientsinside FZ 0% taxes

0% taxes

International Services Suppliers

輸入

請求額について0.5%の税金

フリーゾーン

免税 フリーゾーン内のサービス提供者

フリーゾーン内の顧客

免税

免税

パラグアイ国内のサービス提供者

国際的サービス提供者

輸出Export

Machineries, capital, raw materialenter with 0% of taxes.

・Exchange of goods and services between users inside the FZ

・Raw materials and goods not liable to tax while stored insede FZ

機会、資本材、原材料は免税で輸入

・フリーゾーン内のユーザー間の財とサービス交換・フリーゾーン内で保管中の原材料と財に対する免税

0.5% taxes on invoice value

請求額に対して0.5%

Clients in Paraguay

International Clients

パラグアイの顧客

国際的顧客

最終製品Finished Products

輸入原材料ストック

Stock of imported raw materials and inputs

(FZ = Free Zone)

0% VAT付加価値税免税

0.5%の税金

輸入税免税

輸入税

Taxes of 0.5%0%Im

port tari�

Import t

ari�

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 19: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

Globe designed by Proletkult Graphik, Teddy Bear designed by Alex Hartmann, Barcode designed by Brandon Manning from the thenounproject.com

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

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Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

III. 保税地域(フリーゾーン制度)

パラグアイは商業、工業、サービス企業の設置に必要なフリーゾーン制度を有している。フリーゾーンに進出して、第3国への輸出のみを目的として事業活動を行う企業には、第3国への総輸出額を基に「フリーゾーン税」と呼称される0.5%の税金のみが課せられる。第3国への輸出に加えてパラグアイ国内においても商品又はサービスを販売する企業は、総収入額の中で国内向け販売額が占める割合に応じて法人税(10%)を支払う。本制度の下でフリーゾーンに持ち込まれる機械機器、資本財や原材料には輸入税が課せられることは無い。フリーゾーンの使用者間の財やサービスの交換、並びに原材料と財の保管にも税金が免除される。現在アルトパラナ地方には、二ヶ所のフリーゾーン(保税地域)があります。一つはブラジルとの国境、もう一つはアルゼンチンとの国境です。どちらの地域でも、多くの国際企業が活発に操業を続けています。

V. 輸出インセンティブ

政府は生産の前段階について税の支払い猶予を認めているため、輸出に対する付加価値税支払いが免除される。又、一時的入国を認める制度により、輸入税や付加価値税は免除される。

IV. 工業団地

パラグアイに進出する外国企業に工業団地を提供しています。

この工業団地は便利な交通アクセスの他、電力、水道、高速インターネットなどの必要なインフラを備えております。現在、国営の工業団地がカピアタ市に、また7つの私営工業団地が国内各所にあります。

これらの工業団地の中には港湾使用料や通関手数料に対する優遇措置や、24時間体制のセキューリテイー、特定ニーズのための職業訓練所もあるところもあります。

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

PARQUE INDUSTRIAL MARISCAL FRANCISCO SOLANO LOPEZ – Capiata, Central Deparment

PARQUE INDUSTRIAL PANAMERICANO– Villa Elisa, Central Department

PARQUE INDUSTRIAL S.A. AVAY – Villeta, Central Department

ZONA INDUSTRIAL TROCIUK – Fram, Itapua Department

PARQUE INDUSTRIAL TERMINAL OCCIDENTAL S.A. – Chaco’i, Presidente Hayes Department

PARQUE LOGÍSTICO ITAUGUA – Itaugua, Cordillera Department

ZONA INDUSTRIAL HERNANDARIAS – Hernandarias, Alto Parana Department

COMPLEJO PARQUE MERCOSUR – Ciudad del Este, Alto Parana Department

Active industrial parks in Paraguayパラグアイの工業団地:

1

1

2

2

33

44

5

5

6

6

7

7

8

8Asunción

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 20: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

投資は長期に渡り安定的で持続的な経済成長を可能にするための法的保護を制定する、安定的で確実、かつ、透明な法的枠組みを必要とする。パラグアイは自由貿易に基づく経済制度を有しており、内外のあらゆる投資に完全な門戸を開いている。従って、政府による承認プロセスを必要としない。更に、法規や標準が変更される事が無いよう、完璧な法的安定性が規定されており、投資の進行中、投資家に対して有利な状況を提供する。国家憲法は経済と貿易の自由を保証しており、投資が規制される分野は存在せず、差別的、限定的取り扱いも一切無い。従って、自国民・外国人を問わず、あらゆる個人は国家のモラルや公共の秩序、国の安全に反する事が無い限り、該当の法規を遵守の上、あらゆる経済活動を実施する権利を有する。又、投資法(1991年発布の法律第117号)は以下の原則を定めている:

• 平等:外国投資は国内投資と同等の取り扱いを受ける。従って、外国投資家は差別的な条件を課されることも取り扱いを受けることも無く、又、逆に優先的な扱いを受けることも無い。

• 所有権: 内外投資家は憲法と法律が定める制限の対象物以外のあらゆる土地財産を購入することができる。

• 為替交換の自由:資本の国内外への移動が保証され、すべての為替交換や送金、資金移動に関して法律に規定される税金の支払い以外、配当金、利息、手数料、技術移転その他の事由によるロイヤリティー等の海外送金に対してなんらの規制も無い。

• 内外における投資保険の自由な契約が保証されている。

• 自由交易:以下に記載する内容を含めた自由な交易が保証されている: ▪ 一般的な財やサービスの生産と取引の自由 ▪ 法律の規制対象以外のあらゆる財やサービスの生産と売買   における自由な価格設定 ▪ 法律で禁止される物以外の財とサービスの自由な貿易

• 普遍性:外国投資は国内特別法によって規制される例外を除き、あらゆる部門の経済活動において歓迎される。例外とされる分野としては、監督官庁による許認可又は特定のコンセッション(営業や開発権利の移転)を必要とする炭化水素、鉱物、電気通信、林業などが挙げられる。これらの場合、投資家は、個々に定められる制度に従わねばならない。

• 自動性:上記は例外として, 外国投資家はその他のあらゆる部門への投資が認められており、特別な制度に従わねばならない種類の投資を除き、事前の許認可を求める必要は無い。特別な場合は、個々に定められている制度に準じた手続きが必要となる。

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

E) FOREIGN INVESTMENT PROTECTION AND GOOD BUSINESS ENVIRONMENT

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外国投資の保護と良好なビジネス環境

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

2015年にパラグアイ政府は“投資保障及び雇用と経済、社会、推進法5542/15”を立法化した。この法律は当法律の適用を申請する企業に対し所得税率の不変保障及び政府機関との投資契約により平等で合法的安全を保障する。同様に投資が社会的インパクトを与える場合は利益配当に対する追加所得税の免除や配当送金に課される税に対して50%までの減税などの恩典がある。当法律は新しい投資プロジェクトだけでなく、この法律の施行前のものでも、投資プロジェクトの承認と投資契約の実行も含め、この法律の条件を満たせば適用される。

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

2016年1月、パラグアイは前年度における経済環境指数の平均値がラテンアメリカの中で最高の位置を占めた。この経済環境指数とは著名なヘテウリオ・ヴァルガス財団とミュンヘン大学のレイブニス経済研究所が判定する数値であり、ラテンアメリカ諸国の現状と今後の6か月を見通した上での経済シナリオを基に測定している。

Page 21: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

投資は長期に渡り安定的で持続的な経済成長を可能にするための法的保護を制定する、安定的で確実、かつ、透明な法的枠組みを必要とする。パラグアイは自由貿易に基づく経済制度を有しており、内外のあらゆる投資に完全な門戸を開いている。従って、政府による承認プロセスを必要としない。更に、法規や標準が変更される事が無いよう、完璧な法的安定性が規定されており、投資の進行中、投資家に対して有利な状況を提供する。国家憲法は経済と貿易の自由を保証しており、投資が規制される分野は存在せず、差別的、限定的取り扱いも一切無い。従って、自国民・外国人を問わず、あらゆる個人は国家のモラルや公共の秩序、国の安全に反する事が無い限り、該当の法規を遵守の上、あらゆる経済活動を実施する権利を有する。又、投資法(1991年発布の法律第117号)は以下の原則を定めている:

• 平等:外国投資は国内投資と同等の取り扱いを受ける。従って、外国投資家は差別的な条件を課されることも取り扱いを受けることも無く、又、逆に優先的な扱いを受けることも無い。

• 所有権: 内外投資家は憲法と法律が定める制限の対象物以外のあらゆる土地財産を購入することができる。

• 為替交換の自由:資本の国内外への移動が保証され、すべての為替交換や送金、資金移動に関して法律に規定される税金の支払い以外、配当金、利息、手数料、技術移転その他の事由によるロイヤリティー等の海外送金に対してなんらの規制も無い。

• 内外における投資保険の自由な契約が保証されている。

• 自由交易:以下に記載する内容を含めた自由な交易が保証されている: ▪ 一般的な財やサービスの生産と取引の自由 ▪ 法律の規制対象以外のあらゆる財やサービスの生産と売買   における自由な価格設定 ▪ 法律で禁止される物以外の財とサービスの自由な貿易

• 普遍性:外国投資は国内特別法によって規制される例外を除き、あらゆる部門の経済活動において歓迎される。例外とされる分野としては、監督官庁による許認可又は特定のコンセッション(営業や開発権利の移転)を必要とする炭化水素、鉱物、電気通信、林業などが挙げられる。これらの場合、投資家は、個々に定められる制度に従わねばならない。

• 自動性:上記は例外として, 外国投資家はその他のあらゆる部門への投資が認められており、特別な制度に従わねばならない種類の投資を除き、事前の許認可を求める必要は無い。特別な場合は、個々に定められている制度に準じた手続きが必要となる。

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

19

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V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

2015年にパラグアイ政府は“投資保障及び雇用と経済、社会、推進法5542/15”を立法化した。この法律は当法律の適用を申請する企業に対し所得税率の不変保障及び政府機関との投資契約により平等で合法的安全を保障する。同様に投資が社会的インパクトを与える場合は利益配当に対する追加所得税の免除や配当送金に課される税に対して50%までの減税などの恩典がある。当法律は新しい投資プロジェクトだけでなく、この法律の施行前のものでも、投資プロジェクトの承認と投資契約の実行も含め、この法律の条件を満たせば適用される。

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

メルコスール ビジネス環境のランキング

Source: Getulio Vargas Foundation & Leibniz Institute for Economic Research - January 2016  出所:ジェトゥリオ・ヴァルガス財団 -2016年1月

MERCOSUR Business Environment Index

January 2015 April 2015 July 2015 October 2015

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In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

2016年1月、パラグアイは前年度における経済環境指数の平均値がラテンアメリカの中で最高の位置を占めた。この経済環境指数とは著名なヘテウリオ・ヴァルガス財団とミュンヘン大学のレイブニス経済研究所が判定する数値であり、ラテンアメリカ諸国の現状と今後の6か月を見通した上での経済シナリオを基に測定している。

Page 22: Paraguay land of opportunities

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Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Light Bulb designed by Francesco Terzini, Money Transfer designed by Lemon Liu, sugar cubes by Josue Oquendo, Sugar by Douglas Santos, Mint designed by Botho Willer, Mate designed by Joseph Pearce, Soy designed by Lemon Liu, Oil designed by Edward Boatman, Steak designed by Anuar Zhumaev, Wheat designed by Andrea Caldarelli from the thenounproject.com

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

Paraguay’s International Trade Position 貿易においてパラグアイが占める位置

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

No. 1 largest exporter of clean electricity in the world

No. 2 highest Return on Investment (ROI) for direct foreign investment in Latin America (CEPAL 2014).

世界第1位のクリーン電力の輸出国

No. 4largest exporter of soybean in the world世界第4位の大豆の輸出国

No. 6largest producer of soybean in the world世界第6位の大豆の生産国

No. 6largest exporter of corn in the world世界第6位のとうもろこしの輸出国

No. 4largest exporter of yuca starch in the world世界第4位のユカ(芋)スターチの輸出国

No. 3 largest producer and exporter of yerba mate (ilex paraguariensis) in the world世界第3位のマテ茶葉(ilex paraguariensis)の生産及び輸出国

ラテンアメリカにおいて、外国投資に対する投資回収率(ROI)が第二位(CEPAL2014年)

No. 1 largest exporter of organic sugar有機砂糖生産では世界1の輸出国

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Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 23: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Light Bulb designed by Francesco Terzini, Money Transfer designed by Lemon Liu, sugar cubes by Josue Oquendo, Sugar by Douglas Santos, Mint designed by Botho Willer, Mate designed by Joseph Pearce, Soy designed by Lemon Liu, Oil designed by Edward Boatman, Steak designed by Anuar Zhumaev, Wheat designed by Andrea Caldarelli from the thenounproject.com

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

21

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

No. 1 in currency stability in Latin America

No. 3 largest economic growth in the world in 2013 (13.6%)2013年の世界における経済成長率において第三位(13.6%)

No. 6largest exporter of beef in the world世界第6位の食肉の輸出国

No. 10largest exporter of wheat in the world世界第10位の小麦の輸出国

No. 4largest exporter of soybean oil in the world世界第4位の大豆油輸出国

No. 5largest exporter of soybean expeller in the world世界第5位の大豆搾りかすの輸出国 

No. 3 largest �eet of barges in the world (2,200 barges and 200 tugs), No. 1 USA, No. 2 China.

世界第3位のバージ船(はしけ)の所有国(バージ船2200隻、タグ ボート200隻)第1位はアメリカ合衆国、第2位は中国

No. 2 largest producer and exporter of stevia in the world世界第2位のステヴィアの生産及び輸出国ラテンアメリカにおいて、為替安定率は第一位

Paraguay’s International Trade P

osition

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 24: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

22

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Investment Opportunities投資機会

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 25: Paraguay land of opportunities

Paraguay is part of the MERCOSUR (Southern Cone Common Market) which allows it to have free access to a market of more than 300 million people. With its strategic location, Paraguay is just two hours away by plane from Buenos Aires, Sao Paulo, Montevideo or Santiago. It is located in the center of the bioceanic corridor, currently under construction, which allows easy access to the most important ports and markets of the region, as well as to free ports located both in the Atlantic and in the Pacific Oceans.

Most Paraguayan exports go through the Paraguay-Parana waterway in barges to Buenos Aires, Montevi-deo and Rosario. Local routes connect Asuncion to border cities Ciudad del Este and Encarnacion which allow convenient access to Brazil and Argentina.

Besides being a founder and full member of MERCOSUR (consisting also of Argentina, Brazil, Uruguay and Venezuela), which allows its exports to enter said countries with tari� exemptions, Paraguay is also an o�cial observer to the Pacific Alliance and candidate for future membership.

Since 2014, Paraguay is the only MERCOSUR country with preferential access to the European Union as part of the Generalized Scheme of Preferences (GSP+). Paraguay has been a member of the World Trade Organization since 1995. It has never been involved in disputed cases neither as complainant nor respond-ent.

• Young and trainable labor force: Paraguay has the youngest population in Latin America with 73.7% of them younger than 34 years old. Its labor costs are among the most competitive in the MERCOSUR region.

• Clean electric energy at low cost: Paraguay has the most abundant and one of the cheapest electric energy sources of the MERCOSUR. Electro intensive industries can access the best infrastructure required for their technological development. Paraguay is the biggest exporter of electricity thanks to its three hydroelectric dams: Itaipu, Yacyreta and Acaray, with the possibility of the construction of several others. Itaipu is a binational enterprise between Paraguay and Brazil. It is the world’s greatest hydroelectric dam in terms of power generation, its installed capacity is 14,000 (MG) Megawatts and it produces around 90,000 (GW) Gigawatts/hour. Paraguay only uses around 13% of the energy produced; generating electricity at a very low price. Besides the production of Itaipu, the dam of Yacyreta, built together with Argentina, places Paraguay as the world’s first exporter of 100% renewable energy, free of gas emissions that produce the “greenhouse e�ect”.

• Land: Real estate prices are very competitive. In the past decade, Asuncion was declared the world’s cheapest capital city five times in a row by Mercer Human Resource Consulting.

• Lowest Tax Burden in the Region: Paraguay o�ers a very competitive tax scheme with the lowest rates in the region, which translates in lower production costs for those companies operating within its national territory.

Paraguay o�ers a healthy environment for investment characterized by a predictable economy and controlled level of inflation. In the past decade, Paraguay experienced a solid average economic growth of 5.1% annually, among the highest in the region. In 2014 and 2015, Paraguay's GDP growth was the highest among MERCOSUR countries with 4.7% and 3% respectively.

Paraguay has never experienced high rates of inflation and its currency (the Guarani) recently celebrated its seventieth anniversary, without su�ering any changes of denomination since its conception.

Paraguay o�ers a financial system with a sound capital position and a steady improvement in credit rating, as well as free capital mobility. Average earnings and remittances between 2013 and 2014 were US$853 million.

In 2014, Paraguay with a 22% ROI was the second most profitable country in Latin America for Foreign Direct Investment (FDI). Peru ranked first with 25%. Source: CEPAL (2014’s Regional Forecast)

The Paraguayan tax system is simple and convenient. The investment law grants the same treatment to foreign and local investors. Paraguay has signed security agreements for investments with many coun-tries. There are many special investment regimes, such as the Law 60/1990, the Maquila Regime and the Duty-Free Zones.

I. Law 60/1990 According to Law 60/1990, national or foreign investment projects that are approved for this regime will be exempt from the following charges:

• Fees and internal taxes on the imports of capital goods, raw material and inputs intended for local industry and foreseen in the investment project.

• Value added tax when acquiring capital goods that will be used in industrial, agricultural or livestock production cycle.

• All taxes imposed on the establishment, incorporation and registration of companies or enterprises.

• Taxes on remittances abroad for the payment of interest and commissions and reimbursement of capital (levied on investments over US$5 million).

• Taxes and other fees on remittances abroad for the payment of interest and commissions and reimbursement of capital when the investment is financed from abroad and is more than US$5 million.

Investment projects that want to benefit from this law need to receive approval from the Ministry of Industry and Commerce and the Ministry of Finance.

Eligible InvestmentsThe exemptions established in Law 60/1990 are applicable to investments in financing, capital goods, special-ized technical assistance, mining, hotel, leasing of capital goods, provision of cargo and air passenger transport services, public transportation, health, radio, television, press, rural and urban fixed telephone services, mobile telephone services, scientific investigation, silos, storage and data transmission services, among others.

II. Maquila Regime

Maquila is a production regime in which companies located in Paraguay can produce goods and services for export. The production is done under the request of a foreign company (headquarters) through an international contract, and the production can be sent to any country in the world.

The main benefits this regime o�ers are:

• Exemption of import duties on raw material, inputs, parts and components that enter the country temporarily for their transformation and later export.

• Exemption of import duties on machinery and equipment related to the Maquila activity during the period established in the contract.

• Possibility of national goods and services provision as a complement to the Maquila production system.

• Single tax of 1% to be levied on the value added in national territory or on the value of the invoice issued for and on behalf of the headquarters, whichever greater.

Companies interested in carrying out Maquila activities must present a “Maquila Program” to the National Council for the Maquila Export Industries (CNIME).

Maquila companies with approved programs must provide su�cient guarantee to the General Customs O�ce for the amount of the taxes that may eventually be applicable, which shall be canceled and returned when the temporarily imported merchandise exit the country. Whichever type of guarantee presented – global or floating – it will be exempt from all types of taxes and interests. This guarantee is also applicable when goods, products or services are under the Maquila temporal export regime.

Within MERCOSUR, Paraguay has the most competitive “rules of origin”: up to 60% of inputs can be of extra zone origin, while only 40% of inputs are required to claim MERCOSUR sources origin. This allows tari�-free market access to the entire region.

III. Duty-Free ZonesParaguay o�ers a free trade zones regime for the establishment of commercial, industrial and services enterprises. Companies established in a free trade zone whose activities are focused exclusively on exports pay a single tax of 0.5% of the total value of gross export income, known as “free trade zone tax”.Companies which, beside their exports, also sell their products or services in the Paraguayan territory are subject to Corporate Income Tax of 10% of the proportion of products sold in national territory.Under this regime, machinery, capital goods and raw material enter the Free Trade Zone with a 0% import tax. The commercial exchange of goods and services between Free Trade Zone users, as well the stocking of raw materials and goods, are tax exempt.There are currently two free zones in the region of Alto Parana, bordering Brazil and Argentina, in which several international companies are actively operating.

IV. Industrial Parks Industrial parks o�er a good option for foreign industries to settle in Paraguay in places with good transportation access routes and basic facilities such as electricity, running water, and high-speed internet already in place. Currently, there are eight industrial parks functioning in Paraguay, a public one in the city of Capiata, and seven private ones throughout the country.

Some of these parks also o�er preferential fees in ports and custom brokers’ services, around the clock in-house security and agreements with the National Service for Professional Promotion (SNPP) for training local labor hand into the specific needs of the industries.

In the case of the public industrial park, companies can also receive special municipal tax exemptions and total VAT exemption on the leasing of land plots or infrastructure within its grounds.

V. Exports Incentives

Exports are exempted from paying Value Added Tax (VAT), since the government recognizes a fiscal credit for stages preceding production. There is also a Temporary Admission Regime for imports, which allows the exemption of import duties and VAT.

In 2015, the Paraguayan Government enacted Law 5542/15 “On Investment Guarantees and Promotion of Employment, Economic and Social Development”.This law guarantees the stability of Income Tax rate, equal treatment and legal security for those compa-nies that apply to the regime established therein, through the execution of an investment contract with the government authorities. Likewise, when the investment involves high social impact, the Law foresees additional benefits such as, exemption from additional Income Tax rates on distribution of profits and up to 50% reduction of the withholding tax rate on dividend remittances abroad. The Law is applicable to both new investment projects, as well as investments existing prior to its entry into force, provided such existing investments comply with the requirements set out in the Law, including approval of the investment project and the execution of the investment contract.

23

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Investments need a legal framework that is stable, safe and transparent, that would give legal protec-tion to investors so that the investments could be long term, accomplishing stability and sustainable economic growth with them. Paraguay has an economic system based on free trade and as such there is a total openness to all national and foreign investments – no authorization from the govern-ment is necessary. Furthermore, it has full legal stability because dispositions and economic regulations do not change in an untimely way, an advantageous situation for the investor, having the certainty that in the process of investing the rules will not be changed. The National Constitution guarantees economic and commercial freedom, there are no restricted areas for investment, nor discriminatory treatment or limitations. Therefore, every national or foreign individual has the right to develop any economic activity of their preference as long as it is not contrary to the morals of the nation, public order or national security, respecting the legal norms that regulate it. At the same time, the Investment Law Nr. 117/91 establishes the following principles:

• Equality: Foreign investment receives the same treatment as a national one. Consequently, it is not admissible to impose neither conditions nor discriminatory or favorable treatment to national and or foreign investments.

• Property rights: National and foreign investors can acquire goods and real estate in Paraguay, with no other limitation than the ones established in the Constitution and national laws.

• Free exchange: This law guarantees the inflow and outflow of capital, the remittance of dividends, interests, commissions, royalties for transfer of technology and others without restrictions. However, all foreign exchange transactions, remittances or transfers shall be subject to taxation as established by law.

• Freedom to hire investment insurance locally or abroad.

• Freedom of commerce: ▪ Freedom to produce and commercialize goods and services▪ Free price-setting, with the exception of those goods and services which have production and commercialization regulated by law▪ Freedom to import and export goods and services, with the exception of those prohibited by law

• Universality: Foreign investments are welcome in all sectors of the economy, with the exception of those included in specific local laws, such as: hydrocarbons sector, mining, telecommunications, forestry and others which require special permits, licenses or concessions granted by the local authority.

• Automaticity: With the exceptions aforementioned, foreign investors are authorized to invest in any other sector of the economy without needing prior authorization, unless the investment is subject to a special regime. In such case, the investor must follow the procedures established by such regime.

Paraguay-Japan Commercial Trade パラグアイ - 日本商業貿易

Paraguayan Exports to Japan (USD FOB) 日本への輸出(USD FOB)

日本からの輸入(USD FOB)

パラグアイ - 日本貿易収支

その他の詳細

Paraguayan Imports from Japan (USD FOB)

Balance of Trade Paraguay-Japan (USD FOB)

DISAGGREGATION OF "OTHERS"

2011

SESAME SEEDSゴマ 大豆やその副産物 その他

マテ茶

車両およびそれらの部品

機械および電気機器

ゴム及びその製品

その他

パラグアイ - 日本貿易収支

日本への輸出

日本からの輸入

薬草

ステビア

チアシード

ヨットや他の船舶

その他

MATE TEA

MEDICINAL HERBS

STEVIA

CHIA SEEDS

YACHTS AND OTHER VESSELS

OTHERS

SOYBEAN SEEDS AND ITS BY-PRODUCTS OTHERS

$51,991,129

10M

0

20M

30M

40M

50M

60M

70M

80M

90M

100M

10M

0

20M

30M

40M

50M

60M

70M

80M

90M

100M

110M

120M

0

50M

(80M)

40M

20M

(20M)

(40M)

(60M)

-

100M

$29,216,734

$84,414,977

$105,217,551

$78,730,700

2012 2013 2014 2015

2011 2012 2013 2014 2015

EXPORTS TO JAPAN

VEHICLES AND THEIR PARTS

MACHINERY AND ELECTRICAL EQUIPMENT

RUBBER AND ARTICLES THEREOF

OTHERS

IMPORTS FROM JAPAN

BALANCE OF TRADE PARAGUAY-JAPAN

2011 2012

2014 2015

2013$1,123,497 $793,159

$705,858 $2,270,183

$878,108

2011 2012 2013 2014 2015

$123,403,282

$98,797,340

$73,358,722 $74,527,585

$84,685,263

Source: Central Bank of Paraguay - 2016

In January 2016, Paraguay ranked first in Latin America with the highest average Business Environment Index (BEI) for the past year. The BEI is constructed by the renowned Getulio Vargas Foundation (GVF) and the Leibniz Institute for Economic Research of the University of Munich to measure Latin American countries' current economic scenario and their expected situation in the following six months.

Page 26: Paraguay land of opportunities

パラグアイは安定的な法的枠組みを通じて投資に対し類の無いほどのメリットと高いインセンティブを提供する。

内外投資家に対する税制面を優遇する法律第60号/1990に加え、法律第117号/1991は内外投資家への同一取り扱いを定めており、更に2013年、パラグアイ政府は官民協力法として知られる法律第5102号“公共インフラに対する投資、及び、国有の財とサービスの拡大と改善の促進に関する法律”を承認した。

その結果、数年後、年間総額15億米ドルを超える予定額の大規模公共工事に対して17件以上の施行者選定の為の国際公開入札が召集されることになっている。計画中のすべての公共工事は、20年以上の長期的計画であり、以下の目的を持つ:

・運輸・流通(ロジスティック)用のインフラとサービスの 組織的発展

・効率的で複合的な方法による統合の促進

・我が国の流通(ロジスティック)回廊の多様化

・官民の連帯と権利移譲(コンセッション)を通じて将来の インフラ投資計画を促進

・国際回廊の整備

・両大洋回廊の導入

※過去12年間における公共工事への平均年次投資額は1億8,000万米ドル程度にとどまっていたにも関わらず、2015年から2018年の間はインフラ工事に75億米ドルが投資される予定である。この事実がパラグアイの発展における新しい転機となる事に疑いの余地は無い。

Paraguay o�ers unique advantages and strong incentives for foreign investments through an established legal framework.

Besides Law 60/1990 which o�ers fiscal incentives to national and international investment, and Law 117/1991 which establishes equal treatment to domestic and foreign investments, in 2013 the Government of Paraguay also approved Law 5102 on Investment Promotion in Public Infrastructure, Expansion and Improvement of Goods and Services provided by the Government, also known as Public-Private Partnership Law.

In the next couple of years, more than 17 contracts of major public works with an annual estimated value of over US$1.5 billion are planned to go under public international tender. All of the projected works have an approximate 20-year time horizon and are aimed at:

・Organizing the development of infrastructure, transportation and logistics services of Paraguay

・Promote an e�ective multimodal integration

・Diversify the country’s logistics corridor

・Develop programs for future infrastructure investments through public-private partnerships

・Establish international corridors

・Implement a bioceanic corridor

Between 2015 and 2018, the Government of Paraguay is planning to invest around US$75 billion in infrastructure works, which is remarkable considering that the average public work invest-ment during the last 12 years was below US$180 million per year.

24

Examples of Infrastructure Projects Prioritized by the Paraguayan Government:

The “Golden Triangle” Asuncion-Ciudad del Este-EncarnacionThis program includes more than 800 kilometers of improvements of the current road infrastructure through Public-Private Partnerships or concessions.

Estimated investment: US$1 billion

Parana-Paraguay Waterway With an approximate extension of 1,000 kilometers, the works to be undertaken include maintenance dredging, signage improvement, and strengthening the support system for navigation.

Estimated investment: US$400 million

International Airports Upgrading ProgramsThis program aims to modernize the air transportation system by granting the operation of major airports to the private sector and provide a world class service within a regional hub concept for the transport of passengers and cargo.

Comparative advantage of the airport network in Paraguay:• Annual operating level of 98% due to optimal weather conditions • Flat topography, no more than 100 meters above sea level• Equidistance to the biggest cities in South America

Estimated investment: US$130 million in five years

Commuter Railroads of AsuncionThe objective of this project is to build 44 kilometers of double track lines, with electrical system with third rail, and five terminals. The expected demand is over 50,000 passengers per day.

Estimated investment: US$250 million

Water and Sanitation Projects The objective is to reach 100% coverage of water supply and sanitation services throughout the country.

Estimated investment: US$2.7 billion

パラグアイ政府が優先するインフラプロジェクトの例

アスンシオン-シウダー・デル・エステ-エンカルナシオンの3都市を結ぶ“黄金のトライアングル”におけるインフラ改善本計画は、公民協力とコンセッション方式による現在の道路インフラ、総延長800㎞の整備改善も含む。

予想投資額  10億米ドル

パラナ―パラグアイ河川ルート総延長距離約1,000㎞、工事は開口とメンテナンス用浚渫、信号システムの整備、航行支援システムの改善である。

予想投資額:4億米ドル

国際空港の近代化本計画の目的は民間への主要空港業務の権利譲渡(コンセッション)を通じて、空輸システムを近代化し、乗客、及び、貨物輸送の為の地域内ハブ空港としてのコンセプトに順じた世界レベルのサービスを提供することにある。パラグアイの空港網が有する比較優位性:・最上の気候条件に恵まれることから年間98%の運航率を誇る・海抜100m以下の平坦な地形・南米主要都市からの均一距離

予想投資額:当初5年間で1億3,000万米ドル

アスンシオン市近郊電車本プロジェクトの目的は複軌全長44キロ(第3軌道は電気施設用、5か所のターミナル駅舎含む)の近郊電車の運行である。予測される需要は1日当たり5万人の乗降客である。

予想投資額:2億5,000万米ドル

上下水道マスタープラン目的は上水道供給と下水サービスの国内100%の普及率達成にある。

予想投資額:官民協力による27億米ドル

Private Opportunities in Paraguay

Paraguay’s private sector also o�ers attractive investment opportunities in the following: • Food industry• Textile industry and clothing• Metalwork industry• Wire harnesses and autoparts• Shoes and leather industry• Reforestation• Logistics• Livestock production, slaughter for export• Agricultural transformation (irrigation, quality certification)• Railroad transportation for passengers• Real estate• Agribusiness• Business services• Financial sector

CONCLUSION• Paraguay o�ers the most opportunities and the best investment climate for Japanese companies in South America.

• The Japanese technology, discipline, innovation and leadership, combined with Paraguay’s young and disciplined labor force, energy, natural resources, low tax, expanding markets, and safe macroeconomic environment, o�ers a magnifi-cent opportunity to establish “win-win” alliances.

• All this, in the framework of over 78 years of cooperation and friendship.

パラグアイが民間部門に提供するチャンス

パラグアイの民間部門も又、以下のような魅力ある投資機会を提供している。 • 食料産業• 繊維・アパレル産業• 金属加工業• ワイヤーハーネス及び 自動車部品• 靴・レザー産業• 植林• ロジスティック• 畜産・輸出用家畜 解体業• 農業加工業(灌漑、品質証明) • 鉄道(乗客)運輸業• 不動産• アグリビジネス• ビジネス・サービス.• 金融部門

結論• パラグアイは南米において、日本企業にもっとも多くの チャンスと優れたビジネス環境を提供する国である。

• 日本の技術・規律正しさ・イノベーション・リーダーシップ と、パラグアイによって提供される若く規律正しい労働力 ・エネルギー・自然資源・低率の税金・拡大する市場・健全 なマクロ経済環境の融合は、日本とパラグアイの「ウインー ウイン」同盟関係を築くための素晴らしいチャンスとなる。

• これらすべては、78年にわたる両国の友好・協力関係に よるものである。

Page 27: Paraguay land of opportunities

CONTACT US FOR MORE INFORMATION AND ASSISTANCE

Embassy of Paraguay in [email protected] +81 3 3265 5271

詳しい情報、及び、ご質問のある方は在日パラグアイ大使館とコンタクトをお取りください。

在日パラグアイ共和国大使館[email protected]+81 3 3265 5271

We invite you to visit and invest in “Paraguay, a land of opportunities”「パラグアイ チャンスに満ちた国」へのご招待と投資の誘致

Sources 情報源 : Investment and Exports Network (REDIEX): 投資輸出促進局(REDIEX)www.rediex.gov.py

Ministry of Industry and Commerce:商工省 www.mic.gov.py

Central Bank of Paraguay:パラグアイ中央銀行 www.bcp.gov.py

Ministry of Finance:大蔵省 www.hacienda.gov.py

Ministry of Public Works and Communications:公共事業通信省 www.mopc.gov.py

General Directorate of Statistics, Surveys and Censuses:統計国勢調査局www.dgeec.gov.py

National Council of Maquila Industries Exports (CNIME):国家マキラドーラ産業審議会の執行事務局 www.maquila.gov.py

Page 28: Paraguay land of opportunities

Embassy of Paraguay in [email protected] +81 3 3265 5271

在日パラグアイ共和国大使館[email protected]+81 3 3265 5271