International Trade and Customs Alert - April 2026
For more information, contact:
Themes
Private Special Economic Zones
By Supreme Decree No. 006-2026-MINCETUR, published on April 22, 2026, the Regulations of Law No. 32449 were approved, which establishes the Special Tax and Customs Regime for Private Special Economic Zones (ZEEP).
1. Key aspects of this new regime
The aim is to promote national competitiveness by positioning the country as an industrial hub, in order to attract new private investment, develop high value-added activities, and foster scientific research and technological development.
To this end, the regulation establishes, among others, guidelines on permitted and non-permitted economic activities, the process for qualifying a ZEEP, the requirements to be recognized as an Operator or User of a ZEEP, as well as the applicable tax and customs benefits.
The following key elements are highlighted:
- Reduced (graduated) rates for Corporate Income Tax, applicable for up to 25 years.
- Accelerated annual depreciation of fixed assets.
- Special treatment (exemption) regarding Value Added Tax (VAT) and Excise Tax (ISC).
- Tax and customs stability.
- Special customs regime for the entry and storage of goods.
2. Permitted and non-permitted activities
Permitted activities that may be carried out within the ZEEP:
- Industrial activities: Transformation of raw materials into finished or semi-finished products, including activities under Section C of the International Standard Industrial Classification (Manufacturing Industries).
- Assembly activities: Integration of parts, components, subassemblies, or assemblies resulting in a product with characteristics different from its components, as well as the assembly or adaptation to other goods.
- Services: Support activities for the development of industrial and assembly operations, linked to activities under Section C of the International Standard Industrial Classification (Manufacturing Industries).
Non-permitted activities: activities related to the mining and hydrocarbons industries, financial services, among others. Activities included in a restricted list (such as the manufacture of apparel and footwear, etc.) are also not allowed.
3. Other aspects
- Criteria are established for the qualification of a ZEEP’s location, considering factors such as multimodal logistics connectivity, access to energy and basic services, proximity to productive clusters or value chains, socioeconomic impact, and social and institutional acceptance, among others.
- Criteria are also set to assess applications from bidders seeking to become Private Operators of a ZEEP, taking into account georeferencing, the characteristics and land-use compatibility of the proposed site, environmental and climate risks, financial feasibility and investment structure, as well as SME linkage strategies.
- The regulation outlines the procedures and requirements for applying to qualify a ZEEP, to be recognized as a Private Operator, and to be registered as a User (industrial or services).
- It also establishes the regime of administrative infringements and sanctions applicable to Private Operators.
4. Entry into force
The Regulation discussed herein entered into force on April 23, 2026. Notwithstanding this, the approval by the Ministry of Economy and Finance of complementary regulations on tax and customs matters is still pending.