Peruvian Executive Branch ratifies OECD Multilateral Convention

• On 27 May 2025, the Peruvian Executive Branch approved Supreme Decree 013-2025-RE, ratifying Peru's adherence to the OECD Multilateral Instrument (MLI), which aims to align the country's tax treaty network with international standards on base erosion and profit shifting.
• The implementation of the MLI is expected to modernize Peru's network of Double Tax Treaties, with adjustments likely taking effect from 1 January 2026.
• Companies 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.

On 27 May 2025, the Peruvian Executive Branch (Presidency and Ministry of Foreign Affairs) approved Supreme Decree 013-2025-RE, ratifying the country's adherence to the Multilateral Instrument (MLI) established by the Organisation for Economic Co-operation and Development (OECD), to align the country's existing tax treaty network with the OECD standards on base erosion and profit shifting (BEPS).

The MLI's implementation is expected to modernize Peru's network of Double Tax Treaties (DTTs) by modifying treaties covered under the instrument. Although Peru has not yet deposited the ratification instrument with the OECD, this is anticipated to occur in the coming days. Consequently, the adjustments are likely to take effect as of 1 January 2026.

Peru's DTT network currently includes treaties with Brazil, Canada, Chile, Japan, Korea, Mexico, Portugal, Switzerland, 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.

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.