Peru’s BEPS MLI entered into force on 1 October 2025 to curb tax treaty abuse and base erosion by multinationals.
The Multilateral Convention on Tax Treaty Measures to Counter Base Erosion and Profit Shifting (MLI) has entered into force in Peru today, 1 October 2025.
Peru deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) on 9 June 2025.
The application of the MLI to Peru’s tax treaties depends on ratification by the treaty counterparties. For each treaty, the MLI becomes effective on the first day of the month following a three-month period after both parties have ratified.
Once in effect, the MLI generally applies to withholding taxes from 1 January of the following year and to other taxes for periods starting six months after entry into force. Peru has reserved that for its own application to other taxes, the rules will apply from 1 January of the calendar year after the six-month period.
Earlier, Peru’s Ministry of Foreign Affairs published a notice on 23 August 2025 in a special edition of the Official Gazette regarding the upcoming entry into force of the BEPS MLI.
