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17 June 2025

Peru deposits MLI with OECD

  • On 9 June 2025, Peru deposited the ratification instrument of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD, marking a significant step in Peru's tax treaty compliance.
  • The provisions of the MLI will come into force for Peru on 1 October 2025, with practical effects beginning on 1 January 2026, affecting how Peru's double tax treaties are applied.
  • Peru's current double tax treaty network includes agreements with several countries, but treaties with Japan, the United Kingdom and the Andean Community will not be adjusted under the MLI, as they are not covered treaties.
  • Entities engaged in cross-border transactions should prepare for the upcoming changes in tax treaty provisions.
 

Peruvian President Dina Boluarte, on 9 June 2025, deposited the ratification instrument of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the Organisation for Economic Co-operation and Development (OECD). (For background, see EY Global Tax Alert, Peruvian Congress ratifies the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), dated 17 March 2025.)

The provisions of the MLI will come into force for Peru on 1 October 2025 and take effect as of 1 January 2026.

Peru's double tax treaty (DTT) network currently includes treaties with Brazil, Canada, Chile, Japan, Korea, Mexico, Portugal, Switzerland, the United Kingdom (although not in effect) and the Andean Community (i.e., Bolivia, Colombia and Ecuador). However, it is important to note that the treaties with Japan, the United Kingdom and the Andean Community will not be adjusted through the MLI from the Peruvian standpoint, as they have not been selected as covered treaties.

Entities engaged in cross-border transactions should prepare for the upcoming changes in tax treaty provisions, as the MLI's implementation may affect withholding tax rates and other tax obligations under existing treaties.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young Asesores Empresariales S.C.R.L and Ernst & Young Consultores S Civil de RL, Lima - Peru

Ernst & Young LLP (United States of America), Latin American Business Center, New York

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

Ernst & Young Tax Co., Latin American Business Center, Japan & Asia Pacific

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-1282

 

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