Global Daily Tax News, BEPS MLI In Force For Peru, (Oct 2, 2025)
The BEPS multilateral instrument (MLI) became effective for Peru on October 1, 2025.
The MLI enables countries to modify their existing tax treaties to include measures developed under the OECD/G20 BEPS project without having to individually renegotiate these treaties.
The instrument will implement minimum standards to counter treaty abuse, prevent the artificial avoidance of permanent establishment status, improve dispute resolution mechanisms, and neutralize the effects of hybrid mismatch arrangements.
Jurisdictions may choose, when ratifying the BEPS MLI, which of their treaties they wish to amend through the MLI. These treaties are known as "covered agreements".
Providing the other signatory territory has also selected that agreement as a covered agreement and the BEPS MLI has entered into force for that other signatory territory, the changes will be effective immediately from October 1, 2025.
Peru has selected seven treaties as "covered agreements" for purposes of the BEPS MLI: agreements with Brazil, Canada, Chile, Korea, Mexico, Portugal, and Switzerland.