(i) BEPS Action Plan
The OECD and G20 countries adopted the BEPS Action Plan with the aim of producing a consensus package of international tax rules capable of addressing BEPS (combating Base Erosion and Profit Shifting to non-business substance located in lower tax countries) and protecting tax bases, while providing predictability and legal certainty to taxpayers, without generating double non-taxation, unjustified compliance burdens or restrictions on cross-border activities.
BEPS Project - Explanatory Note | OECD
(ii) Action 15 of the BEPS Action Plan provides for the development and subscription of a Multilateral Instrument that allows States to implement in a rapid, synchronized, and consistent manner, among others, minimum standards developed by the BEPS Action Plan in order to avoid individual renegotiation of treaties.
On June 27, 2018, Peru signed the Multilateral Instrument expressing its position regarding the application of the provisions of said treaty, and its entry into force will be subject to Peru depositing the instrument of ratification with the OECD.
BEPS Multilateral Instrument | OECD
Peru signs convention to combat tax avoidance by multinational companies
(iii) Regarding the minimum standards developed by BEPS linked to treaties, we have BEPS Action 6 that seeks to combat the abusive use of tax treaties and BEPS Action 14 that seeks to make more effective the mechanisms of prevention and resolution of disputes within the framework of the treaties. Both minimum standards will be adopted and implemented in the treaties signed by the country when the Multilateral Instrument is approved and ratified by the Peruvian State.
Action 6 of the BEPS Plan:
Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping | OECD
Action 14 of the BEPS Plan:
Dispute resolution in cross-border taxation | OECD
Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report | OECD