The MAP constitutes part of the minimum standard that Peru assumed as a member of the BEPS Inclusive Framework (BEPS Erosion and Profit Shifting, by its acronym in English) since 2017, in that sense, SUNAT has been promoting the update of the TUO of the Tax Code, the Income Tax Law and its regulations to incorporate provisions that establish the rules applicable to the aforementioned procedure and its effects.
During 2023, SUNAT published the PAM Guideline - Version 1.0 (in Spanish and English), which establishes the rules, guidelines and procedures on the access and use of the MAP, in order to provide clarity, certainty and transparency to those who opt for this alternative dispute resolution mechanism within the framework of the provisions of the DTA.
Guide to the Mutual Agreement Procedure - MAP - Spanish Version
Guide to the Mutual Agreement Procedure - MAP - English Version
In addition, in November 2024, the information on access, resolution and implementation of the MAP provided in the country profile (Peru Dispute Resolution Profile) was updated, complying with the BEPS Action 14 standard, which helped to address the assessment through the Simplified Peer Review Process (SPRP) conducted by the MAP (Mutual Agreement Procedure) Forum of the OECD, which began in July 2023 and was successfully completed in February 2024 with the approval of the Report by the MAP Forum.