Peru has ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) through Supreme Decree No. 013-2025-RE, published in the Official Gazette on 27 May 2025.
Following this ratification, Peru must now submit its ratification instrument for the MLI to take effect for its covered tax treaties. Under the standard MLI framework, the convention enters into force for a specific treaty on the first day of the month after a three-month period from when both treaty parties have deposited their ratification instruments.
Once active, MLI provisions generally apply to withholding taxes starting 1 January of the year following entry into force, while other taxes are subject to the agreement from the beginning of taxable periods that commence at least six months after activation. Peru has reserved that the MLI will apply to other taxes starting 1 January of the next calendar year, following a six-month period after its entry into force.
