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Title page 1

Contents 5

Foreword 4

Abbreviations and acronyms 8

Executive Summary 10

1. Main tax policy challenges 13

Introduction 14

Challenge 1: Peru's tax-to-GDP is low 14

Challenge 2: Tax buoyancy is low 17

Challenge 3: High informality persists 21

Challenge 4: An increasing tendency to introduce tax expenditures 24

Challenge 5: Strengthening the financing of health insurance 28

Challenge 6: Continuing to strengthen tax enforcement 29

Challenge 7: Improving the schedular design of the personal income tax 31

Challenge 8: Strengthening the design of the recently introduced special economic zones 34

Challenge 9: Strengthening the design of the business tax regimes 35

Challenge 10: Strengthening the taxation of the mining sector 37

Challenge 11: Increasing the revenue from indirect taxes 38

Challenge 12: Strengthening the financing of subcentral governments through recurrent taxes on immovable property 40

Reform recommendations 41

References 46

Notes 50

2. Improving tax buoyancy 52

Strengthening the translation of economic growth into revenue growth in Peru 53

Strategies to increase long-run buoyancy and manage volatility in the tax-to-GDP ratio 54

Sector-specific considerations for strategies to increase long-run buoyancy and manage volatility in the tax-to-GDP ratio 60

References 67

Notes 67

3. A balanced approach to tax expenditures in Peru 68

A narrow benchmark and low uptake account for low revenue forgone estimates from TEs in past years, but this may change over time 69

The recent increase in the number of TEs approved presents fiscal risks and governance concerns 70

Reforms could enhance the effectiveness and reduce the fiscal cost of Peru's TE provisions 70

References 80

Notes 81

4. Payroll taxes and mandatory benefits 82

The labour tax wedge in Peru is not particularly high 83

Changes to the basic PIT allowance and the impact on the tax wedge 85

The tax wedge alone does not provide an accurate picture of formal labour costs 86

There could be scope to broaden the PIT and SSC bases, but the impact of these measures on the tax wedge needs to be carefully assessed 88

Tax wedge and labour costs for the self-employed and in special regimes 90

References 95

Notes 95

5. The schedular design of the personal income tax in Peru 97

Comprehensive versus dual PIT systems: general introduction 98

The design of the PIT in Peru 101

The role of income tax withholding and information systems: general introduction 103

The PIT withholding and information system in Peru 105

Reform recommendations to strengthen the PIT in Peru 106

References 109

Note 109

6. The tax design of special economic zones in Peru and peer countries 110

International experience with tax incentives could help inform the tax design in Peru's special economic zones (SEZs) 111

SEZs are not yet a significant feature of Peru's economy 111

The foreseen CIT rate schedule in ZEEPS and its interactions with the GMT 113

Peru's past experience with tax incentives offers important insights for the design of the ZEEPs 114

References 124

Notes 127

Annex A. Empirical evidence on tax incentives 130

Tables 7

Table 1.1. Reform recommendations linked to each challenge 41

Table 3.1. Tax Expenditure Policy Recommendations 71

Table 4.1. Tax and contribution treatment of labour cost components (general labour regime) 89

Table 4.2. Impact of combined reform scenarios on the tax wedge under the general regime 89

Table 4.3. Impact of individual reform scenarios on the tax wedge under the general regime 90

Table 5.1. Approaches to taxing personal income in the OECD 99

Table 5.2. Interaction between corporate and personal level taxation of dividend income 100

Table 6.1. Corporate income tax rates in ZEEPs 122

Figures 6

Figure 1.1. The tax-to-GDP ratio and tax structure in Peru 15

Figure 1.2. Evolution of tax-to-GDP ratio and GDP per capita in Peru, 1990-2024 17

Figure 1.3. Tax-to-GDP ratio, tax buoyancy and copper price over time 18

Figure 1.4. Revenues from the taxation of mining profits and the copper price over time 19

Figure 1.5. Effective CIT rates in Peru, 2024 25

Figure 1.6. Schedular composition of the PIT base across the income distribution (in UIT) 31

Figure 1.7. Effective labour income PIT rates by income category in 2024 33

Figure 1.8. Business taxpayers by regime over time 36

Figure 1.9. Excise tax revenue in Peru as a percentage of GDP 39

Figure 2.1. Buoyancy by tax type 56

Figure 2.2. Tax collection by tax as a percentage of GDP, 2007-2023 56

Figure 2.3. Sectoral CIT revenues to GDP 59

Figure 2.4. Total tax buoyancy in the mining sector and the rest of the economy 60

Figure 2.5. Sectoral decomposition of Peru's tax-to-GDP ratio 61

Figure 2.6. Sectoral decomposition of year-over-year changes in Peru's tax-to-GDP ratio 61

Figure 2.7. Tax revenue growth and value-added growth by sector, 2011-2024 62

Figure 2.8. Sectoral share of GDP vs share of contributions to total tax revenue 63

Figure 2.9. Evolution of value-added growth and sectoral tax revenue to sectoral value-added in agricultural subsectors, 2011-2024 65

Figure 2.10. Total buoyancy by sector, 2016-2024 66

Figure 3.1. CIT effective tax rate under the general and MYPE regime by economic sector 77

Figure 4.1. Tax wedge for a single taxpayer without children with average wage earnings 83

Figure 4.2. Tax wedge progressivity indicator across earnings intervals in Peru 84

Figure 4.3. Simulated impact of basic PIT allowance reforms on the tax wedge by earnings level 85

Figure 4.4. Labour cost of hiring a minimum wage worker in Peru by labour regime in 2026 87

Figure 4.5. Tax and labour regimes in Peru by firm size 92

Figure 4.6. Tax wedge for a single taxpayer by earnings level and labour regime 93

Figure 4.7. Change in the labour cost per worker when growing firms transition between regimes 94

Figure 6.1. Economic activity in SEZs in selected Latin American and Caribbean countries 113

Boxes 57

Box 2.1. Methodology for sectoral tax calculations across tax types and sectoral buoyancy analysis 57

Box 6.1. Private Special Economic Zones (ZEEPs) introduced in 2025 in Peru 121

Infographics 7

Infographic 1.1. Peru's main structural and issue-specific tax policy challenges 14

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