On 9 June 2025, 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), underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. The BEPS Convention will enter into force on 1 October 2025 for Peru.
As of today, 89 jurisdictions have either ratified, accepted, or approved the BEPS Convention resulting in the modification of over 1600 treaties. Around 400 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.
The BEPS Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the BEPS Convention address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements. The BEPS Convention also enhances the tax treaty dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 33 jurisdictions.
The text of the BEPS Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available at www.oecd.org/en/topics/beps-multilateral-instrument.html.
