Investing In... 2026

PARAGUAY TRENDS AND DEVELOPMENTS Contributed by: Federico Valinotti, Andrés Nasser, Álvaro Rojas, Vivian Maldonado and Juan Manuel Ros, BKM - Berkemeyer

standards, with clear provisions on metering, dispatch and safety. The law establishes a mixed incentive framework. On the fiscal side, it cross-references the new invest - ment tax incentives regime (Law No 7548/2025) and complementary instruments, operationalised through annually published, exhaustive lists of eligible equip - ment, such as photovoltaic panels, stationary stor - age, inverters, bidirectional meters, wind turbines and biomass technologies. On the economic side, it intro - duces a reference tariff for surplus injections by self- generators and cogenerators up to defined thresh - olds, credits for injected energy and their assignment, partial reimbursements for network reinforcements, and ANDE procurement through tenders with refer - ence price caps for up to 15 years. Exporters must ensure national energy security and contract trans - mission with ANDE, with competitive allocation of capacity where binding constraints exist. ANDE’s 2024–2043 Master Generation Plan priori - tises: • utility-scale solar PV with storage at designated sites in the Western Region and across central and northern systems; • hybrid PV–diesel solutions for isolated communi - ties in the Chaco; • portfolios of small hydropower plants across multi - ple basins; and • battery banks at strategic nodes to manage inter - mittency and voltage quality. Demand-side management, energy efficiency and loss reduction are core near-term levers to bridge sup - ply-demand gaps while larger projects mature. The integrated approach aims to diversify sources, add capacity on scalable timelines and support a more resilient grid. Cross-cutting implications for investors and market participants Across these reforms, Paraguay emphasises bank - ability, legal certainty and operational readiness.

• The industrial and tax incentives regime lowers entry costs and supports technology-intensive manufacturing and export operations. • The arbitration modernisation enhances dispute resolution predictability with digital integration and strict limits on judicial interference. • Capital market unification facilitates sophisticated financing structures, including DLT-enabled instru - ments and harmonised post-trade infrastructure. • The carbon credit framework creates investable pathways into voluntary and compliance markets, supported by clear governance and methodology validation. In infrastructure, the PPP overhaul and the rail-specific law illustrate complementary strategies: an economy- wide PPP platform with expanded fiscal capacity and lender protections, and a sector-tailored structure with a segregated payment trust and life cycle contract - ing. The NCRE regime expands supply options and diversifies the matrix through a combination of fis - cal incentives, tariff mechanisms and standardised technical and licensing processes. Together, these elements enable consistent risk allocation, strong - er performance regimes and credible payment and enforcement mechanisms, aligning Paraguay’s market with international norms and investor expectations. Competition control: a two-track notification for concentrations The competition authority (CONACOM) approved a new Instruction for Merger Notifications in May 2025 (effective 1 September 2025), introducing ordinary and simplified forms. The simplified track is available under standard low-risk scenarios – limited combined market shares, vertical relationships under a 30% threshold, no nexus between activities, acquisition of sole control from joint control, low turnover targets, or newcos with no initial Paraguayan footprint. The structure preserves the substance of the prior regime but streamlines disclosure under clearly delineated criteria, with shorter evaluation timelines for qualifying transactions. Parties should still expect to substan - tiate market definitions and share estimates where relevant, and to document information sources and methodologies.

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