(Adopted by the Global Forum in June 2026)
Peru joined the Global Forum in 2014. Peru underwent its Second Round of EOIR Peer Review in 2020 (Peru’s 2020 Report),1 which assessed its legal and regulatory framework in force as at 29 December 2019 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 April 2015 to 31 March 2018. Peru received an overall rating of Largely Compliant and the individual Elements were rated as follows:
|
A.1 |
A.2 |
A.3 |
B.1 |
B.2 |
C.1 |
C.2 |
C.3 |
C.4 |
C.5 |
Overall |
|
|---|---|---|---|---|---|---|---|---|---|---|---|
|
Determinations |
i.p.b. |
i.p.b |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
n.a. |
LC |
|
Ratings |
PC |
LC |
C |
C |
C |
C |
C |
C |
C |
PC |
Peru received seven in-box recommendations in relation to Elements A.1, A.2 and C.5.
This monitoring report assesses the actions taken by Peru to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.
The report concludes that two recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation” and the remaining five recommendations are “in the process of being addressed”, and it advises on actions required.
|
Recommendation (A.1, framework) |
Peru should ensure that records containing ownership information of struck-off entities are maintained for a minimum period of five years. |
|
Underlying factor |
Although Peru's law contains a general rule that ensures that ownership information would remain available after an entity ceases to exist, it is not clear how this information will be kept in the case of entities that are liquidated ex-officio under the process established in Legislative Decree No. 1427 of 2018. (see paragraphs 67 to 77 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
In 2022, Peru amended Legislative Decree No. 1427 to designate the person responsible (custodian) for keeping books, records and other documentation of the struck-off entity. The custodian is the entity's general manager or administrator, provided they have an effective designation as of the date on which the annotation of “prolonged inactivity” is made. If there is no general manager or administrator with an effective designation on that date, the most recently registered person will be considered the responsible person. If there is more than one general manager or administrator with equal powers, the responsible person will be the most recently registered before the date when the annotation of “prolonged inactivity” is made, unless their designation was registered on the same date, in which case it will be the first one registered on that day. If a legal entity has been appointed as general manager or administrator, the responsible person will be the last individual acting on its behalf for this purpose, as per the information registered with the National Superintendence for Public Registries . The custodian must retain the records for a period of five years, computed from 1 January of the year following the one in which the entity has been struck off. Noncompliance with this obligation is subject to the tax penalties provided for non-retention of records in the Tax Code. In August 2025, Peru has adopted the regulations determining the practical aspects by which the National Superintendence for Public Registries must provide the Tax Administration with the identity of custodians of books, records and other documentation of struck-off entities every six months, consolidating the information from the entities struck-off in the previous six months. The National Superintendence for Public Registries must submit the first batch of information to the Tax Administration in two groups in January and February 2026 depending on when the entity was struck off . To control compliance with this obligation, Peru plans to carry out a set of supervisory measures throughout 2026 and 2027. |
|
Conclusions |
Peru appears to have taken appropriate actions to address the recommendation. The amendments introduced by Peru address the legal gaps identified in the 2020 Report, as they clarify who is responsible for retaining the ownership information of entities that have been struck off. While some supervisory actions have been scheduled, the implementation and enforcement in practice of these amendments are yet to be ascertained. Therefore, Peru is expected to report progress on the implementation of the changes in the legal and regulatory framework under Recommendation 2 (see below). |
|
Status determined |
Considered provisionally addressed in the context of the monitoring process, subject to detailed validation |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (A.1, practice) |
Peru should monitor the risk that entities not registered with SUNAT [the Tax Administration] pose to the availability of information and ensure that the new strike-off rules are being effectively carried out. |
|
Underlying factor |
There is a significant percentage of companies and partnerships with legal existence and legal personality not registered with the tax authorities. Whilst some of these may not perform economic activity, this high number, together with the reduced number of sanctions imposed by SUNAT [the Tax Administration], during the review period, on entities that did not comply with the obligations to register or update information, poses a risk that the ownership information would not be available for a significant set of entities. The government issued Legislative Decree No. 1427 which introduced a mechanism that allows SUNARP [the Registry of Companies] to declare ex officio the extinction of companies and partnerships with “prolonged inactivity”. Nonetheless this mechanism is not yet operational. (see paragraphs 51 to 56 and 65 to 76 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
Peru implemented actions to monitor the risk of entities not registered with the Tax Administration, through cross referencing information from the tax database with information from the public registry of companies. As a result, Peru has identified the universe of unregistered entities and applied regularisation measures, including strike-off procedures. The percentage of entities not registered with the Tax Administration reduced from 22% as on 31 March 2018 to 2% as on 31 December 2024. Peru has struck off 182 116 entities from 1 January 2020 to 31 December 2024 due to prolonged inactivity, thus depriving them from legal personality. In addition, for entities whose strike-off procedure has not yet been concluded Peru has carried out monitoring activities by contacting their partners; having covered 87% of these companies as of 31 December 2024. Finally, Peru reported a scheduled supervision programme with planned actions to be undertaken throughout 2026 and 2027. |
|
Conclusion |
Peru has made progress to address the recommendation. While it is positive to note that Peru has significantly reduced the number of entities that retain their legal personality despite not being registered with the Tax Administration, further information is required on the supervision activity undertaken to ensure that the strike-off rules are being effectively carried out, including the amendments adopted in 2022 to Legislative Decree No. 1427 (see Recommendation 1). Peru should report further progress in its next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (A.1, practice) |
Peru is recommended to put in place a supervision and enforcement programme of implementation of the legal requirements in Legislative Decree No. 1372 for legal entities and arrangements (including “irregular companies”) to request and maintain beneficial ownership information, and report it to SUNAT [the Tax Administration], as well as the implementation by SUNAT [the Tax Administration] of the centralised registry with beneficial ownership information. |
|
Underlying factor |
So far, only the AML framework ensured the keeping of beneficial ownership information in Peru. Since there is no requirement for all entities and arrangements to engage with an AML obliged person in a continuous relationship, the AML Law does not ensure the availability of beneficial ownership information in all relevant cases. Recently, Legislative Decree No. 1372 established the obligation for all legal entities and arrangements to request and maintain beneficial ownership [information] and to submit this information to a centralised registry kept by SUNAT [the Tax Administration]. Nonetheless, the centralised registry is not yet operational, and the monitoring of the new requirements has not yet started. (see paragraphs 98 to 101 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
The implementation of the centralised register has been carried out progressively by taxpayer segments based on income levels. For the first four taxpayer groups (representing domestic legal entities with income above 300 tax units (1 380 000 PEN (Peru’s currency: the Peruvian sol) or 316 514 EUR, considering the tax units of 2022 and the conversion rate applicable for that year), the average compliance rate is 94%. This high level of compliance has been achieved through a combination of voluntary compliance, persuasive measures (e.g. communications and awareness) and corrective measures (e.g. penalties). As of December 2025, penalties have already been applied to the first segment of taxpayers (large taxpayers), while for the other segments the corresponding penalty processes are ongoing. The fifth group corresponds to domestic legal arrangements which had to submit information for the first time in October 2024. While the compliance rate is low at 30%, Peru has initiated compliance actions aimed at increasing this rate (persuasive actions to encourage voluntary compliance prior to initiating the corresponding sanctioning procedure). Moreover, Peru has set the deadlines for the remaining domestic legal entities (i.e. those with incomes below 300 tax units) to submit the beneficial ownership information, with submission dates ranging from November 2025 to December 2026. Finally, the Tax Administration is in the process of implementing a resolution to cover the remaining universe of entities and arrangements (i.e. foreign ones). Peru plans to carry out a set of supervisory measures throughout 2025 and 2026 to verify compliance with the obligation to have up-to-date information and check the adequacy and accuracy of the beneficial ownership information reported. |
|
Conclusion |
Peru has made progress to address the recommendation. Five groups of domestic legal entities and legal arrangements have been required to submit their beneficial ownership information to the Tax Administration. For the first four groups (domestic legal entities with income above 1 380 000 PEN (316 514 EUR)) the average compliance rate is94%, through a combination of voluntary compliance, persuasive measures (e.g. communications and awareness) and corrective measures (e.g. penalties). For the fifth group (domestic legal arrangements), while the compliance rate is low (30%), Peru has initiated compliance actions aimed at increasing this rate. The remaining group of domestic legal entities is required to provide their beneficial ownership information from November 2025 to December 2026. For the segment of foreign legal entities and arrangements, the Tax Administration is in the process of implementing a resolution to set a deadline to submit their beneficial ownership information to the Tax Administration. For the time being, actions undertaken have focused mainly on the submission of beneficial ownership information to the centralised register. While the Tax Administration has programmed some supervision activities aimed at assessing the quality of the information provided, these have not yet been implemented. In the context of the implementation of these measures, some areas are to be further considered, including the absence of a mechanism to compel beneficial owners to disclose the relevant information to the entity/arrangement and the absence of discrepancy reporting systems in the ability to cross-check beneficial ownership information from other sources in practice. |
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Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (A.2, framework) |
Peru should ensure that accounting records and the underlying documentation of struck-off entities are maintained for a minimum period of five years. |
|
Underlying factor |
Although Peru's law contains a general rule that ensures that accounting records and underlying documentation would remain available after an entity ceases to exist, it is not clear how this information will be kept in the case of entities that are liquidated ex-officio under the process established in Legislative Decree No. 1427 of 2018. (see paragraphs 77, 153, and 156 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
See actions reported under Recommendation 1. |
|
Conclusion |
Peru appears to have taken appropriate actions to address the recommendation. The amendments to Legislative Decree No. 1427 address the legal gaps identified in the 2020 Report, as they clarify who is responsible for retaining the accounting information of entities that have been struck off. While some supervisory actions have been scheduled, the implementation and enforcement in practice of these amendments are yet to be ascertained. Therefore, Peru is expected to report progress on the implementation of the changes in the legal and regulatory framework under Recommendation 5 (see below). |
|
Status determined |
Considered provisionally addressed in the context of the monitoring process, subject to detailed validation |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (A.2, practice) |
Peru should monitor compliance by companies with their record keeping obligations to ensure that reliable accounting records are kept for all relevant entities and arrangements. |
|
Underlying factor |
There is a high number of entities registered with the Registrar of Companies (SUNARP) that are not registered with the tax administration (SUNAT) and are therefore not subject to its monitoring activities. The high level of informality and the low level of sanctions imposed by SUNAT to entities that do not register or update their information can lead to cases in which non-registered entities are operating in the informal economy without being effectively monitored. Accounting records for these entities may not exist. (see paragraph 162 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
See actions reported under Recommendation 2 regarding the actions planned to supervise that records of struck-off companies are duly maintained; for accounting records these actions are expected throughout 2026 and 2027. |
|
Conclusion |
Peru has made progress to address the recommendation. While it is positive to note that Peru has significantly reduced the number of entities that retain their legal personality despite not being registered with the Tax Administration, further information is required on the supervision activity undertaken to monitor that accounting records are kept in line with the standard, including for companies that have been struck-off. Peru should report further progress in its next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (C.5, practice) |
Peru should ensure that its internal EOI procedures are effectively applied and the time limits are respected in order to be able to respond to EOI requests in a timely manner. |
|
Underlying factor |
Over the review period, Peru has not always answered EOI requests in a timely manner. (see paragraphs 289 and 290 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
The Tax Administration continues to improve its internal procedures, including communication with audit areas, to increase timeliness in obtaining the information requested. Furthermore, the Tax Administration continuously work in reinforcing the training on EOI matters to contribute to the effective application of internal EOI procedures. |
|
Conclusion |
Peru has made progress to address the recommendation, but there is still room for improvement in the timeliness of responses. Peru should report further progress in its next self-assessment. |
|
Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment, Peru should –
|
|
Recommendation (C.5, practice) |
Peru is recommended to improve communication with partners, adequately inform them when a request is declined for valid reasons and send status updates whenever it cannot answer within 90 days. |
|
Underlying factor |
During the review period, Peru rarely provided a status update to its EOI partners within 90 days when the competent authority was unable to provide a substantive response within that time. In addition, Peru did not communicate adequately to an EOI partner that requests were declined for valid reasons. (see paragraphs 291 to 293 of the Peru’s 2020 Report for more information) |
|
Summary of actions reported |
The Tax Administration supervises compliance with its internal EOI procedures to ensure that (i) status updates are sent in all cases within 90 days where a complete final answer cannot be sent within 90 days and (ii) any case of valid rejection is properly communicated to the requesting partner with the accompanying explanation of the rejection and evidence where needed. During the monitoring period, Peru did not reject any request and while it has sent status updates in all cases, these were not always sent within 90 days. |
|
Conclusion |
Peru has made progress to address the recommendation. No peer has raised any communication issues with Peru and the proportion of required status updates that were sent improved, from 10% during the review period covered in the 2020 Report to 31% during the monitoring period 2023-2024. Peru should report further progress in its next self-assessment. |
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Status determined |
In the process of being addressed |
|
Actions required |
In its next self-assessment, Peru should –
|
Over the monitoring period, Peru received 24 requests and sent 241 requests. Ecuador, Spain and Panama were the top three partners in respect of incoming requests. Cayman Islands, China and Panama were the key partners in respect of outgoing requests. Peru reported providing full and final responses in 88% of all the received requests and indicated 8% as pending requests. The remaining 4% corresponds to requests withdrawn by the requesting jurisdiction.
Eight members provided peer input on Peru. Peers reported general satisfaction in respect of their EOIR experience with Peru. One peer mentioned that status updates for incoming requests were not provided systematically, as it indicated having received them “generally” rather than “in all cases”. There is a pre-existing recommendation on the issue of systematic provision of status updates, and Peru is required to report further progress on it in its next self-assessment.
No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Peru or have otherwise come to light.
Peru should continue taking actions towards implementing the standard effectively.
The following next steps are expected from Peru:
Submit the next self-assessment in 2028 under the second round of enhanced monitoring.
See also Chapter 1 (Scope and Methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.
Peru would like to express its gratitude to the Global Forum Secretariat, the Peer Review and Monitoring Group members, and all jurisdictions for their contributions during the enhanced monitoring process.
Peru would also like to reaffirm its commitment to standard of transparency and exchange of information on request for tax purposes; therefore, Peru will continue working to address the recommendations to achieve full compliance with that standard.
← 1. OECD (2020), Global Forum on Transparency and Exchange of Information for Tax Purposes: Peru 2020 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/f1554 34a-en.