The Peruvian Congress approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 13 March 2025.
Following the internal ratification process, Peru must deposit its ratification instrument to bring the MLI into force for its covered tax treaties. The convention will generally take effect for a specific tax treaty on the first day of the month following a three-month period after both treaty parties have completed the deposit of their respective ratification instruments.
Once in force, the MLI provisions will apply to withholding taxes from 1 January of the year following its entry into force. For other taxes, the convention will take effect for taxable periods beginning on or after the expiration of a six-month period from the date of entry into force.
However, Peru has opted for a reservation under which the MLI will apply to other taxes only for tax periods beginning on or after 1 January of the following calendar year, following a six-month period after its entry into force.
The ratification of the MLI demonstrates Peru’s commitment to combating tax avoidance and ensuring the integrity of its tax system by incorporating Base Erosion and Profit Shifting (BEPS) measures into its tax treaty network.
Earlier, the Economy, Banking, Finance, and Financial Intelligence Committee of the Peruvian Congress approved a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 6 November 2024.