Peru will implement the BEPS Multilateral Instrument from 1 October 2025, with application to tax treaties depending on counterparties’ ratifications.
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 Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI).Peru deposited its instrument of ratification on 9 June 2025. The MLI will take effect for Peru on 1 October 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 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, underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises.
