On 23 August 2025, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), of the Organisation for Economic Co-operation and Development (OECD), was published in the Official Gazette El Peruano.

Peruvian President Dina Boluarte deposited the ratification instrument of the MLI with the OECD on 9 June 2025. (For further details, see EY Global Tax Alert, Peru deposits MLI with OECD, dated 17 June 2025.)

The MLI was previously ratified through Supreme Decree No. 013-2025-RE and will enter into force on October 1, 2025. (For further details, see EY Global Tax Alert, Peruvian Executive Branch ratifies OECD Multilateral Convention, dated 17 March 2025.)

The MLI will amend Peruvian taxation (withholding on Peruvian source income) of non-Peruvian residents under the Double Tax Treaties between Peru and Canada, Chile, Korea, Mexico and Portugal as of January 1, 2026.

The MLI provisions 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.

For further details, 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.

Contact information

Please list the name(s) of those who materially participated in the drafting and review of this posting in the order they are to appear. Include the name of the group to which they belong, keeping in mind that the group names often does not match the Alert category (e.g., AM&I Alerts are published by the National Quantitative Services group.)

For joint Alerts, please indicate the group(s) to which the contact(s) belong and which group should appear first. Please do not enter "Standard." If there are no contacts, leave this section blank.