Peru establishes a new Private Special Economic Zones regime with up to 25-year tax incentives

BY JESÚS A. RAMOS AND
PAOLA DE LA CRUZ ROJAS

Peru has enacted the regulatory regime for the creation and operation of Private Special Economic Zones (Zonas Económicas Especiales Privadas, or ZEEP), a measure designed to attract investment through tax, customs, and trade incentives.

Through Supreme Decree No. 005-2026-MINCETUR, published on April 22, 2026 in the official gazette, the Ministry of Foreign Trade and Tourism (MINCETUR) established the rules governing these zones. ZEEPs may be proposed and developed by private investors, subject to a technical approval process.

Gradual corporate income tax treatment

The regime includes a reduced corporate income tax (CIT) rate for up to 25 years. Companies operating within a ZEEP will be subject to a zero percent CIT rate during the first five years. The rate will gradually increase to a maximum of 15 percent by year 25, which is approximately half of Peru’s standard corporate tax rate.

With respect to value-added tax (VAT), the regime provides that certain transactions conducted within a ZEEP, as well as services exchanged with foreign parties, will not be subject to VAT. However, VAT will be applicable to transactions originating from the ZEEP into the domestic market.

Customs framework

The regime includes a customs framework that allows for the entry, storage, and exit of goods under specified conditions. Transactions from the rest of Peru into a ZEEP are treated as exports, which may be relevant for companies engaged in international markets.

Authorization and operational requirements

The establishment of a ZEEP is subject to a multi-stage approval process, including a technical evaluation of the proposed area, authorization of a private operator – who must commit a minimum investment of 1,500 tax units (Unidad Impositiva Tributaria, or UIT) – and formal delimitation of the zone by supreme decree.

Companies seeking to operate within a ZEEP must commit a minimum investment of 2,000 UIT within a two-year period, conduct their core activities within the zone, and comply with financial reporting and operational requirements.

Permitted activities

The regime permits industrial, manufacturing, logistics, technology, and export-related services within ZEEPs. Certain activities are excluded, including mining, hydrocarbons, financial services (subject to limited exceptions), and direct sales to end consumers.

Implementation and oversight

The regime declares the establishment of at least one ZEEP in each region of Peru, including the Constitutional Province of Callao, to be of national interest. MINCETUR will oversee the authorization, supervision, and enforcement of ZEEPs in coordination with Peru’s tax authority.

Considerations

The new regime may create opportunities for structuring investments under a potentially more competitive tax and operational regime. Careful legal and tax planning, as well as ongoing compliance with regulatory requirements, are relevant considerations for effective use.

Jesús Ramos is a partner with DLA Piper in Lima, Peru and advises in corporate and international taxation, tax litigation, tax planning, taxation of economic groups, and taxation of digital businesses.

Paola De la Cruz Rojas is a senior associate with DLA Piper in Lima, Peru and has nearly 10 years of experience advising companies in various sectors, including technology, foreign trade, digital business, mining, hydrocarbons, engineering, and tourism.

This overview was originally published by DLA Piper. Republished with permission from DLA Piper.

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