Reconstructing the treaty network

This report has been prepared taking into account the directives and guidelines provided by the general reporters and by IFA. The purpose of this report is to review the impact of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("MLI") on the structure and operation of the tax treaty network. The report will assess the direct influence of the MLI on Covered Tax Agreements, its indirect influence on the negotiation of bilateral tax treaties and issues relating to the practical implementation of the MLI.

Peru wants to be an OECD member by 2021. In this light, Peru has adopted relevant BEPS measures as the approval of a full flesh GAAR; and, it will replace interest deduction based on a ratio of equity (3:1) to a percentage of tax EBITDA. Furthermore, transfer-pricing rules are extensive and regularly subject to tax audit assessments. and procedures for exchange of information and mutual assistance between Tax Administrations have been included. Finally, rules on identification nof beneficial lowners will become effective and applicable for Peruvian entities, trust, and funds, as of 2019.

See complete chapter at: Cahiers de droit fiscal international. Volume 105, International Fiscal Association, 2020.